Mr. Rick Dumas
UPS Supply Chain Solutions
One UPS Way
Champlain, NY 12919

RE: The tariff classification of two abrasive articles from China

Dear Mr. Dumas:

In your letter dated December 27, 2011, on behalf of A Richard Tools, you requested a tariff classification ruling on three products including a Drywall Aluminum Pole Sander (item number 18310), a Professional Sponge Sander (item number 18270) and a Professional Sponge Sander (item number 18271). The Drywall Aluminum Pole Sander (item number 18310) was addressed under ruling N202163 dated February 16, 2012. Item numbers 18270 and 18271 are the subject of this ruling. These two samples were sent to our U.S. Customs and Border Protection Laboratory for analysis. Our laboratory has now completed its analysis.

The merchandise under consideration consists of two sponge head sanders. Item number 18270 is a rectangular (two-sided) sponge head sander and item 18271 is a triangular (three-sided) sponge head sander labeled as corner sander. Each sponge head contains an abrasive powder of corundum (aluminum oxide) glued to a base of synthetic polymer. Each sponge head sander includes metal hardware which enables the product to be attached to a handle.

 Analysis of each sample taken by our laboratory is consistent with your description of its composition.

The applicable subheading for the two Professional Sponge Sanders (item numbers 18270 and 18271) will be 6805.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for natural or artificial abrasive powder or grain, on a base of other materials: other. The rate of duty will be free.

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 Jacob Bunin at 646-733-3027.


Thomas J. Russo
National Commodity Specialist Division