CLA-2-39:S:N:N1-F:238 869601

Mr. Irwin P. Schumer
Permagile Industries Inc.
101 Commercial Street
Plainview, NY 11803

RE: The tariff classification of RTV-801, a silicone polymer, from Taiwan.

Dear Mr. Schumer:

In your letter dated December 5, 1991, you requested a tariff classification ruling.

The product in question, which you refer to as "RTV-801 Silicone Rubber", is a silicone polymer. RTV (Room Temperature Vulcanizable) systems, in general, consist of silicone polymers which are generally cured by a peroxide (non-sulfur) based curing system. You state that RTV-801 is used to make molds, which are, in turn, used in the manufacturing of a two-part Permagile product ("system"). The applicable subheading for this product will be 3910.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for silicones in primary forms. The rate of duty will be 3 percent ad valorem. This merchandise may be subject to the regulations of the Environmental Protection Agency, Office of Pesticides and Toxic Substances. You may contact them at 402 M Street, S.W., Washington, D.C. 20460, telephone number (202) 554-1404) or EPA Region II at (908) 321-6669.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Sincerely,

Jean F. Maguire
Area Director
New York Seaport