Ms. Colleen Campbell
Engineered Coated Products
369 Elgin Street
Brantford, Ontario, Canada N3S 7P5

RE: The tariff classification of Kleenwrap and Kleenrunner polyethylene film from Canada

Dear Ms. Campbell:

In your letter dated October 4, 2007, you requested a tariff classification ruling.

The sample swatch submitted with your request is identified as Kleenwrap and Kleenrunner. You describe it as CLAF/LDPE/CLAF, a product consisting of a low density polyethylene (LDPE) laminate between two clear cross laminated airy fabric (CLAF) layers. CLAF is plastic film that is mechanically slit into a network of interconnected fibrils. In this case the CLAF is polyethylene. One CLAF layer is cross bonded to the other layer by means of a middle polyethylene laminate. Though you refer to the CLAF layers as nonwovens, and though the material gives an appearance of being made of manmade fiber strips, CLAF split film consists of a single plastics unit, with no individual fibers, filaments, or strips contributing to its existence. The CLAF/LDPE/CLAF sheeting is shipped in roll form in varying widths and lengths. The product is used by construction companies as a disposable protective floor covering.

The applicable subheading for the Kleenwrap and Kleenrunner polyethylene sheeting will be 3920.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics, noncellular and not reinforced, laminated, supported or similarly combined with other materials: of polymers of ethylene. The general rate of duty will be 4.2 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at

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.


Robert B. Swierupski
National Commodity
Specialist Division