Ms. Ami Barone
721 Logistics, LLC
300 Stevens Drive, Suite #105
Lester, PA 19113

RE: The tariff classification of roofing material from Ukraine.

Dear Ms. Barone:

In your letter dated January 6, 2017, you requested a tariff classification ruling on behalf of your client, Realty 360 LLC.

The merchandise under consideration is referred to as APP Fiberglass. A sample was submitted with your ruling request and was forwarded to the Customs and Border Protection Laboratory for analysis. This analysis has been completed.

In your ruling request you state that the APP Fiberglass consists of a non-woven fiberglass sheet soaked and coated in atactic polypropylene-APP modified bitumen. One side of the material is coated with sand, while the other is coated with a thin polyethylene plastic film. The APP Fiberglass is imported in rolls which measure 10 meters long by 1 meter wide by 4 millimeters in thickness, and is designed as a roofing material.

Laboratory analysis has determined that the sample does not contain a continuous fiberglass sheet. Rather, it contains parallel bundles of glass fibers, spaced approximately 8 millimeters apart, which run in only one direction. These bundles of glass fibers are mixed with hydrocarbons; as both bitumen and polypropylene consist of hydrocarbons, the lab is unable to confirm the exact composition of this material.

The APP Fiberglass is a composite good comprised of different materials which are classifiable under different headings. Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 3(b) of the HTSUS provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The bitumen provides the essential character of this item.

The applicable subheading for the APP Fiberglass will be 6807.10.0000, HTSUS, which provides for “Articles of asphalt or of similar material (for example, petroleum bitumen or coal tar pitch): In rolls.” The general 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 Nicole Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division