CLA-2-38:OT:RR:NC:N3:139

Ms. Eileen Family
Geodis USA
5101 South Broad Street
Philadelphia, PA 19112

RE: The tariff classification of Ebecryl ® 856, and Additol ® VXW 6208

Dear Ms. Family:

In your letter dated February 8, 2021, you requested a tariff classification ruling on behalf of Allnex.

The merchandise in question is a resin called Ebecryl ® 856, which is manufactured in Belgium, and a coating additive called Additol ® VXW 6208, which is manufactured in Austria.

You suggested classification in heading 3907 as other polyethers, stating the two products are prepolymers. This office disagrees. While these products are mixtures of multiple prepolymers and other reactive diluents, you state that no polymerization or reaction will take place until after importation when the products will be further processed. Each component, on its own would be considered to be a prepolymer, however, together they are more appropriately described as a mixture. Therefore, the products are excluded from classification in 3907.

The applicable subheading for Ebecryl ® 856, and Additol ® VXW 6208 will be 3824.99.2890, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Mixtures containing 5 percent or more by weight of one or more aromatic or modified aromatic substances: Other: Other. The rate of duty will be 6.5% ad valorum.

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 John Bobel at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division