CLA-2-39:OT:RR:NC:N1:421

Tasha Ekman
Alpha ProTech Engineered Products, Inc.
301 South Blanchard Street
Valdosta, GA 31601

RE: The tariff classification of roofing underlayment from India

Dear Ms. Ekman:

In your letter dated January 19, 2017 you requested a tariff classification ruling. A representative sample was submitted with your request and was destroyed upon examination.

The product to be imported is described as synthetic roofing underlayment. Imported in master rolls with widths ranging from 36-60 inches, this underlayment is comprised of a polypropylene woven fabric coated with a polypropylene film on one side and an adhesive layer with a protective release liner on the other.

You suggest classification in subheading 3919.10, Harmonized Tariff Schedule of the United States (HTSUS), as Self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, whether or not in rolls: In rolls of a width not exceeding 20 cm (7.87”). However, based on the information provided, these master rolls are clearly wider than 20 cm (7.87”).

The applicable subheading for the roofing underlayment will be 3919.90.5060, HTSUS, which provides for Self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, whether or not in rolls: Other: Other: Other. The rate of duty will be 5.8 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 https://hts.usitc.gov/current.

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 April Cutuli at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division