CLA-2-34:RR:NC:SP:236 F87501

Mr. Peter A. Martin
Vorys, Sater, Seymour and Pease LLP
1828 L Street NW, 11th Floor
Washington D.C. 20036-5109

RE: The tariff classification of Christo-Lube MCG109, MCG111, MCG132, MCG133 and MCG138 from Italy

Dear Mr. Martin:

In your letter dated May 17, 2000, on behalf of your client, Lubrication Technology Inc., you requested a tariff classification ruling. The samples submitted are as follows:

MCG109 is comprised of perfluorinated polyether and fluoropolymer. The product is used as a lubricant in vacuum system in the Semiconductor Industry.

MCG111 is comprised of perfluorinated polyether fluorocarbon and fluoropolymer. The product is used primarily as a grease lubricant in oxygen systems, electrical switches, medical tools, and other applications requiring a chemical inert lubricant with a wide operating temperature range and low vapor pressure.

MCG132 is comprised of perfluorinated polyether fluorocarbon and fluoropolymer. The product is used primarily as a grease lubricant in high temperature bearing in corrugators, and other applications that require a high temperature chemically inert lubricant.

MCG133 is comprised of perfluorinated polyether fluorocarbon and fluoropolymer. The product is used mainly as a grease lubricant in the semiconductor industry.

MCG138 is comprised of perfluorinated polyether fluorocarbon and fluoropolymer. The product is used primarily as a grease lubricant in electrical contacts.

The applicable subheading for the MCG109, MCG111, MCG132, MCG133 and MCG138 will be 3403.19.5000, Harmonized Tariff Schedule of the United States, which provides for Lubricating preparations (including cutting –oil preparations, bolt or nut release preparations, antirust or anticorrosion preparations and mold release preparations, based on lubricants) and preparations of a kind used for the oil or grease treatment of textile materials, leather, furskins or other materials, but excluding preparations containing as basic constituents, 70 percent or more by weight of petroleum oils or oils obtained from bituminous minerals. The rate of duty will be 1.4 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 Deborah Walsh at 212-637-7062.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division