CLA-2-35:RR:NC:SP:237 H88695

Mr. Jim Wickstead
Circle International Inc.
491 Supreme Drive
Bensenville, Illinois 60106

RE: Classification of Hermafix glue dispenser and Hermafix refill roll from Germany.

Dear Mr. Wickstead:

In your letter dated February 18, 2002, on behalf of Centis Inc. of Los Angeles, California, you requested a tariff classification ruling. The Hermafix glue dispenser consists of a hand held plastic dispenser, containing a roll of adhesive transfer tape, a take-up reel and a roller. The adhesive tape consists of a strip of glassine paper having an outer film of plastic coated with pressure-sensitive adhesive glue spots and measures 9mm wide by 15m long. When the dispenser is rolled along a surface, the adhesive glue spots are laid onto the surface, and the spent tape, which acts as a carrier for the adhesive, winds onto the take-up reel. The Hermafix refill roll, also measuring 9mm by 15m, will be sold to the ultimate consumer in individual units.

The applicable subheading for the Hermafix glue dispenser and the Hermafix refill roll will be 3506.10.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: other products suitable for use as glues or adhesives, put up for retail sale as glues or adhesives, not exceeding a net weight of 1 kg. The rate of duty will be 2.1 percent ad valorem.

Importations from Germany under subheading 3506.10.5000, HTSUS, (other than animal glue, including casein glue, but not including fish glue) may be subject to a temporary 100 percent ad valorem rate of duty modification for products of the European Community under subheading 9903.02.47, HTSUS. 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. For any questions regarding the ruling, contact National Import Specialist Frank Cantone at 646-733-3038.

Sincerely,


Robert B. Swierupski
Director, National Commodity
Specialist Division