CLA-2-39:RR:NC:TP:221 A86417

Ms. Angel L. Cooper
A.N. Deringer, Inc.
173 W. Service Road
Champlain, NY 12919

RE: The tariff classification of "Norex" butyl coated polyvinyl chloride (PVC) foamed extrusions, "Norseal" PVC foamed sheet and strip, and "Norprene" extruded foam.

Dear Ms. Cooper:

In your letter dated July 22, 1996, on behalf of Norton Company, you requested a tariff classification ruling.

Three samples were submitted with your letter. The Norex butyl coated PVC foamed extrusions are used as a sealant or caulking compound for recreational vehicle van high-tops. The Norseal PVC foamed sheet is self-adhesive. It will be imported in rolls of lengths from 50 to 200 feet and widths from 4 to 56 inches. The Norseal is used in die cut applications, vibration dampening and metal to metal sealing. Norprene is an extrusion made of polypropylene/EPDM used a deformable seal between surfaces. The country of origin is not stated in your letter. The rates of duty provided below are the rates for countries eligible for Most Favored Nation treatment.

The applicable subheading for the Norseal foamed sheet and strip, when imported in rolls of a width not exceeding 20 centimeters, will be 3919.10.2055, Harmonized Tariff Schedule of the United States (HTS), which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, in rolls of a width not exceeding 20 cm: other. The rate of duty will be 5.8 percent ad valorem.

The applicable subheading for the Norseal foamed sheet and strip, when imported in rolls of a width exceeding 20 cm in width, will be 3919.90.5060, HTS, which provides for self- adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, other. The rate of duty will be 5.8 percent ad valorem.

The applicable subheading for the Norex butyl coated PVC foamed extrusions is 3214.10.0010, HTS, which provides for glaziers' putty, grafting putty, resin cements, caulking compounds and other mastics...caulking compounds. The rate of duty will be 3.7 percent ad valorem.

Before we can issue a ruling on the Norprene foam sealant, we need a breakdown showing the weight of the polypropylene versus the weight of the EPDM rubber. Describe the function of each of these materials.

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 212-466-5580.

Sincerely,

Roger J. Silvestri
Director
National Commodity
Specialist Division