CLA-2-35:OT:RR:NC:N3:135
Mr. Rafael Miner
Interexpress LLC
11905 Sara Road E1 Portal Industrial Park
Laredo, TX 78045
RE: The tariff classification of LESA 74070 and LESA 74071 from Canada or Mexico
Dear Mr. Miner:
In your letter dated March 12, 2018, you requested a tariff classification ruling. Your inquiry was submitted to the U.S. Customs and Border Protection laboratory for analysis. Additional information was provided via email on September 21 and 22, 2018. The analysis is now complete.
The products under consideration are BETAMATE™ LESA (low energy substrate adhesives) 74070 Adhesive and LESA 74071 Curative, which are two components of an adhesive system designed for structural applications in automotive manufacturing. LESA 74070 Adhesive is black paste composed of 50-60 percent tetrahydrofurfuryl methacrylate (CAS# 2455-24-5), 15-25 percent styrene butadiene rubber (CAS# 9003-55-8), and less than 10 percent each of 1,3-butadiene, homopolymer, carboxyterminated, ester with glycidyl methacrylate (CAS# 68649-04-7), 2-methylacrylic acid (CAS# 79-41-4), acrylic acid (CAS# 79-10-7), methyl methacrylate (CAS# 80-62-6), calcium carbonate (CAS# 471-34-1), and talc (CAS# 14807-96-6). It is packed in a 47-lb plastic container. LESA 74071 Curative is white paste consisting of 60-70 percent methyl methacrylate (CAS# 80-62-6), 20-30 percent styrene, methyl methacrylate, butadiene polymer (CAS# 25053-09-2), and less than 10 percent each of tributylborane (CAS# 122-56-5) and amorphous silica (CAS# 7631-86-9). It is packed in a 39-lb plastic container. Based on the documents provided, “the adhesive and curative are pumped from bulk containers and mixed in a 1:1 ratio immediately prior to application or mixed together in a specially-designed 400-ml cartridge for smaller applications. The adhesive is applied and cured (hardened) at room temperature (15–35°C or 60–95°F) for two to six hours. Once cured, BETAMATE LESAs form a permanent bond.”
You seek the classification of each component when presented separately and the classification of both components when presented together as a kit.
The applicable subheading for LESA 74070 Adhesive when imported seperately will be 3506.99.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Prepared glues and other prepared adhesives, not elsewhere specified or included …: Other: Other.” The general rate of duty will be 2.1 percent ad valorem.
The applicable subheading for LESA 74071 Curative when imported seperately will be 3815.90.5000, HTSUS, which provides for “Reaction initiators, reaction accelerators and catalytic preparations, not elsewhere specified or included: Other: Other.” The general rate of duty will be 5 percent ad valorem.
The applicable subheading for LESA 74070 Adhesive and LESA 74071 Curative when imported together as a kit will be 3506.99.0000, HTSUS, which provides for “Prepared glues and other prepared adhesives, not elsewhere specified or included …: Other: Other.” The general rate of duty will be 2.1 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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division