CLA-2-39:RR:NC:TP:221 A82462

Ms. Sandra Liss Friedman
Barnes, Richardson & Colburn
475 Park Avenue South
New York, NY 10016

RE: The tariff classification of "Coffi" protein film from Germany.

Dear Ms. Friedman:

In your letter dated March 27, 1996, on behalf of the Brechteen Company, you requested a tariff classification ruling.

The product, identified as "Coffi," consists of a thin edible protein film imported in rolls, made from cattle hide collagen. The corium layer of the hide is washed, treated with lime, rewashed, and then placed in an acid solution to promote swelling and water absorption. Next, the hide is cut, ground into a slurry, diluted with water, and homogenized. The slurry is then extruded into a flat sheet, heat cured and humidified.

You state that the heat treatment results in the creation of crosslinks between functional groups of adjacent amino acids as well as on a supra-molecular level, between fibrils and fibers. The New York Customs Laboratory has reviewed the technical literature submitted with your request, and confirms that, based on the information received from the manufacturer, the product has been crosslinked to produce a hardened protein.

You suggest classification in subheading 3917.10.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for tubes, pipes and hoses...artificial guts (sausage casings) of hardened protein or of cellulosic plastics materials...of collagen. However, that provision is limited to tubular products. The applicable subheading for the Coffi, imported in the form of film or sheet on rolls, will be 3920.99.2000, HTS, 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 other plastics...flexible, other. The rate of duty will be 4.2 percent ad valorem.

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 212-466-5580.


Roger J. Silvestri
National Commodity
Specialist Division