CLA-2-40:OT:RR:NC:N4:421

Mr. Christopher Reynolds
Barthco International, Inc. dba OHL-International
5101 S. Broad St.
Philadelphia, PA 19112-1404

RE: The tariff classification of rubber bands from Sri Lanka and Thailand

Dear Mr. Reynolds:

In your letter dated December 21, 2011, on behalf of Frank W. Winne & Son, Inc., you requested a tariff classification ruling.

Four samples were provided with your letter and will be returned as requested. Item number 1 is identified as “Mover Bands” manufactured in Sri Lanka. The mover bands are large bands composed of vulcanized natural rubber with a pasted joint. The mover bands are designed for use by moving companies to secure blankets and other protective material around furniture when being moved to prevent damage. Item number 2 is identified as “Pallet Bands” manufactured in Sri Lanka. The pallet bands are large bands composed of vulcanized natural rubber with a pasted joint. The pallet bands are designed to secure goods that are being placed on a pallet for shipping, holding them in place to prevent shifting in transport. Item number 3 is identified as “Crepe Rubber Bands” manufactured in Thailand. The crepe bands, sometimes labeled “Winmore Rubber Bands,” are composed of vulcanized natural rubber with a seamless joint. The crepe bands are designed for a wide variety of general uses, but are most commonly used for bundling paper or stationery items. Item number 4 is identified as “Tie Down/Tarp Straps” manufactured in Sri Lanka. The tie down/tarp straps are made of vulcanized natural rubber. A metal S-shaped hook is affixed through a hole at each end of the strap. The S-shaped hook can be removed; however, in doing so, much of the functionality is lost. The tie down/tarp straps are frequently used in the trucking industry for general cargo control but are general purpose articles with a wide range of applications. The applicable subheading for all four styles of rubber bands will be 4016.99.3500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized rubber other than hard rubber: other: of natural rubber: other. The 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 http://www.usitc.gov/tata/hts/.

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 (646) 733-3023.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division