CLA-2-68:OT:RR:NC:N1:128

Mr. William E. Cole
The White Tool and Supply Company
7207 Chagrin Road, Unit 8
Chagrin Falls, OH 44023

RE: The tariff classification of abrasive discs and backing pads from China.

Dear Mr. Cole:

In your letter dated May 17, 2018, you requested a tariff classification ruling.

The merchandise under consideration is two styles of abrasive discs referred to as Gold Paper Disc, model number Y399, and Green Film Disc, model number G369, and two styles of backing pads. Samples were submitted with your ruling request and will be returned to you.

The Gold Paper Disc and Green Film Disc both measure approximately 5 inches in diameter. The Gold Paper Disc is comprised of a paper backing coated on one side with aluminum oxide abrasive grain, while the reverse features a hook-and-loop surface. The Green Film Disc is comprised of a polyester film backing coated on one side with either aluminum oxide abrasive grain or a mix of aluminum oxide and zirconium corundum abrasive grains. The back of the disc features a hook-and-loop surface.

The 5” diameter backing pads are designed to be attached to hand held power tools called orbital sanders. When in use, a pad is attached to the power tool. A sanding disc is then attached to the pad. The pads are available in two models in order to accommodate the various types of sanding discs. Each pad weighs 3.5 oz. The first model features a vinyl face to which a sanding disc that has a pressure sensitive backing (“PSA”) can be attached. The second model is composed of a molded polymer construction with a backing that allows the user to attach a disc with a hook and loop system.

The applicable subheading for the Gold Paper Disc, model number Y399, will be 6805.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Natural or artificial abrasive powder or grain, on a base of textile material, of paper, of paperboard or of other materials, whether or not cut to shape or sewn or otherwise made up: On a base of paper or paperboard only.” The general rate of duty will be Free.

The applicable subheading for the Green Film Disc, model number G369, will be 6805.30.5000, HTSUS, which provides for “Natural or artificial abrasive powder or grain, on a base of textile material, of paper, of paperboard or of other materials, whether or not cut to shape or sewn or otherwise made up: On a base of other materials: Other.” The general rate of duty will be Free.

The applicable subheading for the Backing Pads described above for use with pneumatic hand held power tools will be 8467.92.0090, HTSUS, which provides for “Tools for working in the hand, pneumatic, hydraulic or with self-contained electric or nonelectric motor, and parts thereof: Parts: Of pneumatic tools: Other.” The general rate of duty will be Free. The applicable subheading for the Backing Pads described above for use with hand held power tools with self-contained electric motors will be 8467.99.0190, HTSUS, which provides for “Tools for working in the hand, pneumatic, hydraulic or with self-contained electric or nonelectric motor, and parts thereof: Parts: Other … Other.” The general rate of duty will be Free.

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 the 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 Nicole Sullivan at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division