Ms. Jennifer Keller
Patch Products, Inc.
1400 E. Inman Pkwy.
Beloit, WI 53511

RE: The tariff classification of EVA crepe rubber sheets from China

Dear Ms. Keller:

In your letter dated February 28, 2011, you requested a tariff classification ruling.

The product is identified as Rubalon EVA crepe rubber imported in sheet form. Rubalon is a foam material made of EVA (ethylene vinyl acetate) plastics blended with rubber. It is used for applications such as shoe soles, floor mats, mouse pads and puzzle toys. According to the breakdown submitted with your request, the imported sheets contain 40 percent by weight EVA, 20 percent by weight isoprene rubber, 30 percent by weight calcium carbonate filler, and small percentages of other ingredients. This formulation is considered to be of plastics rather than of rubber for tariff purposes. The sheets measure 43 inches by 48 inches, and will be imported in various thicknesses. After importation the sheets will be die cut into puzzle pieces, game pieces or game boards.

The applicable subheading for the EVA crepe rubber sheets will be 3921.19.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other plates, sheets, film, foil and strip, of plastics: cellular: of other plastics. The rate of duty will be 6.5 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