CLA-2-39:OT:RR:NC:N5: 137
Érola Sabatino
Arkema Inc.
900 First Avenue
King Of Prussia, PA 19406
RE: The tariff classification of butadiene, methyl methacrylate, styrene copolymers from the Netherlands
Dear Ms. Sabatino:
In your letter dated July 2, 2025, you requested a tariff classification ruling.
Clearstrength E920 is described as a core-shell impact modifier and is a butadiene, methyl methacrylate,
styrene copolymer. It is composed of 85 percent butadiene, 10 percent methyl methacrylate and 5 percent
styrene. It is designed to provide excellent ambient and low temperature toughness as well as maximum
impact to polycarbonate, polyesters and a variety of polycarbonate blends. The product is imported in the
form of white powder or pellets. It is recommended for use in automotive applications, electrical and
electronic components and polycarbonate parts.
Clearstrength C303H is described as a core-shell impact modifier and is a butadiene, methyl methacrylate,
styrene copolymer. It is composed of 65 percent butadiene, 8 percent methyl methacrylate and 27 percent
styrene. It is designed to provide impact strength and transparency to polyvinyl chloride (PVC) film and
sheets. The product is imported in the form of white powder. It is recommended for use in high quality PVC
films, sheets and bottles.
The applicable subheading for the butadiene, methyl methacrylate, styrene copolymers will be 3902.90.0050,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for polymers of propylene or of
other olefins, in primary forms: Other: Other. The general rate of duty will be 6.5 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries,
including the Netherlands, will be subject to an additional 10 percent ad valorem rate of duty. Your product
falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable
to your product classification, i.e. 9903.01.32, in addition to subheading 3902.90.0050, HTSUS, listed
above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Christina Allen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division