CLA-2-39:RR:NC:SP:221 R01491

Mr. Dennis Forhart
PricewaterhouseCoopers
1420 Fifth Avenue, Suite 1900
Seattle, WA 98101

RE: The tariff classification of O-rings.

Dear Mr. Forhart:

In your letter dated February 16, 2005, on behalf of Novellus Systems, Inc., you requested a tariff classification ruling.

Diagrams and descriptive literature were provided with your letter. The O-rings will be used as vacuum seals with semiconductor manufacturing equipment. O-ring 22-152842-00 is composed of silicone. O-ring 78-2744 is composed of Chemraz, a perfluoroelastomer. O-ring 21-104462-00 is composed of Viton, a fluorocarbon elastomer.

The country of origin was not stated in your letter. The rate of duty provided below is the rate applicable for the goods when made in a country with which the United States has Normal Trade Relations.

The applicable subheading for the O-rings will be 3926.90.4510, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of plastics and articles of other materials of heading 3901 to 3914: other: gaskets, washers and other seals…O-rings. The rate of duty will be 3.5 percent ad valorem.

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,

Robert B. Swierupski
Director,
National Commodity
Specialist Division