Ms. Etsuko Wilson
Calsak Corporation
1225 W. 190th Street, Suite375
Gardena, CA 90248

RE: The tariff classification of EMI shielding film from Japan

Dear Ms. Wilson:

In your letter dated November 16, 2007, you requested a tariff classification ruling.

The sample submitted with your request is described as electromagnetic interference (EMI) shielding film, or high transparent and conductive film. The film is composed of polyethylene terephthalate (PET). It is coated with ink and copper in a grid-like pattern by means of a printing and plating method. The PET layer accounts for 62.7 percent of the weight of the product while the ink and copper coating accounts for 37.3 percent of the weight. The film will be imported both with and without an adhesive backing.

The film is imported in the form of sheeting measuring 1 meter in width and 100 meters in length. The sheeting is sold to a precision sheet fabricator who slits the film to size and combines and laminates it with other LCD materials. The EMI film is combined with components such as polarized film, glass, liquid crystals and a back light panel to form an assembled LCD panel, e.g., for computer displays, cell phone displays or digital television displays. The EMI film helps to dissipate the electromagnetic interference generated by the electronic circuits in the display/monitor. The copper layer protects the user from electromagnetic waves and the black layer reduces the effects of glare.

You suggest classification in subheading 8529.90.5300, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts suitable for use solely or principally with the apparatus of headings 8525 to 8528: flat panel screen assemblies. The EMI shielding film is imported in material lengths. The dimensions of the articles to be made from the material are not fixed and certain. The film does not have the essential character of the finished article but remains mere material. Thus, the film cannot be considered to be either a part or an unfinished part. Furthermore, the flat panel screen assemblies of heading 8529 must contain drive and control electronics, while the imported film contains none of these components.

The applicable subheading for the EMI shielding film, when imported with an adhesive backing, will be 3919.90.5060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, whether or not in rolls: other: other. The rate of duty will be 5.8 percent ad valorem.

The applicable subheading for the EMI shielding film, when imported without the adhesive backing, will be 3920.62.0090, 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 poly(ethylene terephthalate)…other. The 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