CLA-2-32:RR:NC:SP:237 J88497

Ms. Cindy Johnson
C.H. Powell Company
3340-D Greens Road, Suite 710
Houston, Texas 77032

RE: The tariff classification of oil based adhesive putty strips from Sweden.

Dear Ms. Johnson:

In your letter dated September 5, 2003 on behalf of Monier Lifetile PLC you requested a tariff classification ruling for Rufa Ridge Putty strips which are described as an adhesive and weather preventive matter used to adhere roofing products to their structures. The product consists essentially of drying oils, fillers and hardeners. The applicable subheading for the Rufa Ridge Putty strips will be subheading 3214.10.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other mastics. The rate of duty is 3.7 percent ad valorem. This merchandise may be subject to the requirements of the Toxic Substances Control Act, administered by the U.S. Environmental Protection Agency. You may contact them at 402 M Street, S.W., Washington, D.C. 20460, phone (202) 554-1404. 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 should be provided with the entry documents filed at the time merchandise is imported. If you have any questions on the ruling, contact National Import Specialist Frank Cantone at 646-733-3038.

Sincerely,


Robert B. Swierupski
Director, National Commodity
Specialist Division