Mr. Troy Crago-Edwards
Import Administrator
Northrop Grumman Aerospace Systems
700 North Douglas, Building 902
Mail Drop MT/W10
El Segundo, California 90245

RE: The tariff classification of Technical Grade Petrolatum VV-P-236 (CAS-8009-03-08) from various countries.

Dear Mr. Crago-Edwards:

In your letter dated April 30, 2012 you requested a tariff classification ruling. You provided MSDS and Product Data sheets for our review.

Red Petrolatum, Part Number VV-P-236, is a Technical Grade Petroleum Jelly that meets Federal Specification VV-P-236 for Technical Petrolatum. The product consists of a brownish-red grease-like petroleum jelly in the form of a smooth, semi-solid mixture of mineral oil and waxes. The product has a melting point of 135F and a congealing point of 120F. Federal Specification VV-P-236 requires a Worked Cone Penetration of 150-175. Technical Grade Petrolatum typically exhibits a density of 5mg/cubic meter. The product is used as a light grade of lubricating grease and may be used as a constituent in certain types of rust preventative compounds. Technical Petrolatum is used to protect components during injection repair of internal delaminations, ground support access door seal replacement, stabilizer ventral fins installation and wing fuel tank access panel installation. The product will be imported in 7.5 pound size containers.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the HTSUS. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings at the international level. See T.D. 89-80, 54 Fed. Reg. 35127 (Aug. 23, 1989). EN 27.12 (A) provides: Petroleum jelly is unctuous to the touch. It is white, yellowish or dark brown in colour. It is obtained from the residues of the distillation of certain crude petroleum oils or by mixing fairly high viscosity petroleum oils with such residues or by mixing paraffin wax or ceresine with a sufficiently refined mineral oil. The heading includes the jelly, whether crude (sometimes called petrolatum), decolourised or refined. It also covers petroleum jelly obtained by synthesis. To fall in this heading petroleum jelly must have a congealing point, as determined by the rotating thermometer method (ASTM D 938), of not less than 30C, a density at 70C of less than 0.942 g/cubic meter, a Worked Cone Penetration at 25C, as determined by the method ASTM D 217, of less than 350, a Cone Penetration at 25C, as determined by the method ASTM D 937, of not less than 80.

The applicable subheading for Red Technical Grade Petrolatum VV-P-236 (CAS-8009-03-08) will be 2712.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Petroleum jelly. The rate of duty will be free.

This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U. S. Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460, by calling the TSCA Assistance Line at (202) 554-1404, by Fax at (202) 554-5603, by e-mail to: [email protected] or by visiting their website at

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 Frank Cantone at (646) 733-3038.


Thomas J. Russo
National Commodity Specialist Division