CLA-2-40:OT:RR:NC:N4:421

Mr. David Paul Welch
PanelClaw, Inc.
1600 Osgood Street
North Andover, MA 01845

RE: The tariff classification of styrene butadiene rubber pads

Dear Mr. Welch:

In your letter dated April 10, 2012, you requested a tariff classification ruling.

The pads are composed of non-cellular vulcanized styrene butadiene rubber (SBR). Photographs of the pads were submitted with your letter. The rubber pads are comprised of a flat base with engineered protrusions. The pads are designed to be used as roof protection in a solar photovoltaic mounting system. Their function is to provide a cushion when placed between the roof and the solar panels.

The applicable subheading for the vulcanized styrene butadiene rubber pads will be 4016.99.6050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: other: other. The general rate of duty will be 2.5 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. You did not identify the country of origin. The rate of duty provided above is the rate applicable to this product when it is made in a country with which the United States has Normal Trade Relations.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Joan Mazzola at (646) 733-3023.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division