CLA-2-84:RR:NC:1:103 A88878

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, between .035 and .197 inch in thickness, and will have one or both edges bevelled at an angle between 30 and 90 degrees. 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. Depending on the application in which they will be used, the blades may be made of the following materials:

1. A1 superpolyset (high density polyethylene reinforced with fiberglass)

2. A3 polyset (high density natural polyethylene)

3. B3 superepoxy (epoxy resin reinforced with glass fiber)

4. B5 phenoset (phenolic resin stratified with cotton fibers).

In a telephone conversation with the concerned National Import Specialist, you stated that A1 superpolyset and A3 polyset blades are principally used in the wet end of a papermaking machine, while B3 superepoxy and B5 phenoset blades are principally used in the dryer section of a papermaking machine. The applicable subheading for the unfinished A1 and A3 doctor blades will be 8439.99.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of machinery for making paper or paperboard. The rate of duty will be free.

The applicable subheading for the unfinished B3 and B5 doctor blades will be 8419.90.2000, 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 rate of duty will be 1.4 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on unfinished B1 carboset (epoxy resin stratified with glass fiber, reinforced by carbon fiber) doctor blades. Your request for a classification ruling should include a sample of this material, a statement as to the percentage by weight of the glass and carbon fibers, and a statement as to the material from which the carbon fibers were derived.

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