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NY A80770





August 12, 1996

CLA-2-32:RR:NC:FC:236 A80770

CATEGORY: CLASSIFICATION

TARIFF NO.: 3214.10.0020

Mr. G.P.Singh
Director
GP Technical Service Inc.
7322 Ridgeberry Drive
Houston, Texas 77095

RE: The tariff classification of MM-Metal SS-Steelceramic with Yellow Hardener, MM-Metal OL-Steelceramic with Red Hardener, MM-Metal UW with Hardeners 3 and 9, Ceramium and Hardener CE and VP 10-500 A&B from Germany

Dear Mr. Singh:

In your letter dated February 19,1996, you requested a tariff classification ruling.

The samples submitted are as follows:

1. MM-Metal SS-Steelceramic with Yellow Hardener is a two-part system consists of (a) an epoxy resin, stainless steel powder and compounds of silicon and aluminum, and (b) diethylenetriamine and phenol. The two parts are mixed to form a cement used in the repair and maintenance of metal and alloy parts and equipment.

2. MM-Metal OL-Steelceramic with Red Hardener is a two-part system consists of (a) an epoxy resin, stainless steel powder and compounds of silicon and aluminum, and (b) a polymercaptan resin and a modified amine hardener. The two parts are mixed to form a cement used in sealing metal and alloy parts and equipment contaminated with oil, grease or fuel.

3. MM-Metal UW with Hardeners 3 and 9 is a three-part system consists of (a) a powdered stainless steel and (b) two formulations of a polyester resin dissolved in an organic solvent. The three parts are mixed to form a cement used in the repair of metal and alloy parts and equipment that are damp or located under water.

4. Ceramium with Hardener CE is a two-part system consists of (a) an epoxy resin, stainless steel powder and compounds of silicon and aluminum, and (b) diethylenetriamine and phenol. The two parts are mixed to form a cement used in surface protection and rebuilding of worn metal and alloy parts and equipment.

5. VP 10-500 (A and B) is a two-part system consists of (a) an epoxy resin and compounds of silicon and aluminum, and (b) methyl-5-norbornene-2-3 dicarboxlic acid anhydride and compounds of silicon and aluminum (used to hardener when mixed with (a)). The two parts are mixed to form a cement used in mending of metal and alloy parts and equipment at temperatures of up to 500 degrees centigrade.

The applicable subheading for the each of the above described products when imported with their Hardeners will be 3214.10.0020, Harmonized Tariff Schedule of the United States, which provides for glaziers' putty, grafting putty, resin cements, caulking compounds and other mastics; painters' fillings; nonrefractory surfacing preparations for facades, indoor walls, floors, ceilings or the like: Glaziers' putty, grafting putty, resin cements, caulking compounds and other mastics; painters' fillings.:Mastics: Other. The rate of duty will be 3.7 percent ad valorem.

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 V. Gualario at 212-466-5744.

Sincerely,

Roger J. Silvestri
Director

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