CLA-2-84:RR:NC:1:103 A88877

Mr. Jeffrey J. Shortess
Bonetti Steel Co., Inc.
2920 Wolff St.
Racine, WI 53404

RE: The tariff classification of unfinished doctor blades from Italy

Dear Mr. Shortess:

In your letter dated September 30, 1996 you requested a tariff classification ruling.

Literature submitted with your inquiry describes a doctor blade as a component of a doctor blade assembly which is used in various sections of papermaking and paper finishing machines. The doctor blade assembly is a mechanical device which holds the doctor blade at a uniform pressure against the surface of a rotating cylinder. The scraper action performed by the doctor blade keeps the surface of the cylinder free of pulp, dirt, and other contaminants, and also lifts the paper sheet from the cylinder in the event of a sheet break.

The doctor blades about which you have inquired will be 3 inches in width and between .035 and .197 inch in thickness, will have one or both edges bevelled at an angle between 30 and 90 degrees, and will be made of B7 epoxy (epoxy resin stratified with glass fibers). The blades will typically be imported in lengths of 10 meters, and your firm will trim one end of the blade by a maximum of 1 meter in order to produce the final length required by the customer. In a telephone conversation with the concerned National Import Specialist, you stated that B7 epoxy blades are principally used in the dryer section of a papermaking machine.

The applicable subheading for unfinished B7 doctor blades will be 8419.90.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of machinery and plant for making paper pulp, paper or paperboard by a process involving a change of temperature such as drying. The duty rate will be 1.4 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on unfinished doctor blades made of BR abrasive (epoxy resin stratified with glass fibers and reinforced with silicone carbide) and C1 super carboset (carbon fiber with epoxy resin). Your request for a classification ruling should include a statement as to the percentage by weight of the components of these blades, as well as samples of the BR and C1 materials. In addition, please provide statements as to the material from which the carbon fiber in the unfinished C1 blade is derived, whether the unfinished BR blade has been shaped and then fired, and, if so, the temperature at which it was fired.

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 Alan Horowitz at 212-466-5494.

Sincerely,

Roger J. Silvestri
Director
National Commodity
Specialist Division