CLA-2-39:OT:RR:NC:N2:237
Cindy Johnson
Global trade Compliance Specialist
FMC Technologies Incorporated
5875 N. Sam Houston Parkway
Houston, Texas 77086
RE: Tariff classification of a silicon-based resin filled with glass microspheres from England.
Dear Ms. Johnson:
In your letter dated February 11, 2014 you requested a tariff classification ruling.
Novolastic is a room-temperature vulcanizing silicone resin compounded with hollow glass microspheres designed to reduce density and lower thermal conductivity. The glass microspheres are relatively thick-walled and provide good crush strength and buoyancy. The filled resin is used in casting syntactic silicone foam block, sheet or custom shapes that provide thermal insulation of equipment, subsea christmas trees, manifolds, jumper piping, sleds and similar components. The insulation is pliable and allows for thermal or mechanical expansion or movement of piping such as flowline jumpers without cracking or breaking the insulating layer. Fluids are produced at high temperatures and equipment must be capable of handling extremely hot fluid while submersed in water close to freezing. Subsea lines are insulated to maintain produced liquid hydrocarbons at a sufficiently high temperature to prevent precipitation of wax and formation of gas hydrates, particularly during a production shutdown.
The applicable subheading for the silicon-based resin filled with hollow glass microspheres will be 3910.00.0000, Harmonized Tariff Schedule of the United State, which provides for: Silicones in primary forms. The rate of duty will be 3% ad valorem.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U. S. Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460, by calling the TSCA Assistance Line at (202) 554-1404, by Fax at (202) 554-5603, by e-mail to: [email protected] or by visiting their website at www.epa.gov.
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 Frank Cantone at (646) 733-3038.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division