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September 8, 1999

CLA-2-59:RR:NC:TA:350 E86020

CATEGORY: CLASSIFICATION

TARIFF NO.: 5911.10.2000

Mr. James S. OÂ’Kelly
Barnes, Richardson & Colburn
475 Park Avenue
New York, NY 10016

RE: The tariff classification of “Kinyo Board” press pad material, from Japan.

Dear Mr. OÂ’ Kelly:

In your letter dated August 17, 1999, on behalf of Mitsui & Co. (U.S.A.) you requested a classification ruling.

The instant sample, described in your letter as “Kinyo Board”, is a multi-layered built up or sandwiched type constructed product. It consists of what you describe as high quality heat-press board material made from heat resistant fluoridated elastomer (believed to be a plastics substance) and heat-resistant nylon man-made fiber fabric. The heat resistant nylon fabric is woven and is found on either side of the material. Two additional woven plies are embedded in the elastomer material separated by a thin layer of the plastic elastomer film. There are seven distinct layers in all. You indicate that the nylon portion gives the board high strength and resistance to stretching and the elastomer gives the board excellent cushioning capability.

This “board” material is used in the electronics industry in the manufacture of what is known as PWB’s, i.e., printed wiring boards, where the the PWB materials are cushioned by the Kinyo board in the pressing operation. The manufacturer gives the following weights for the Kinyo board:

Kinyo board 4.05 kg/
Elastomer 3.15 kg/ (77.8%)
Nylon Material 0.9 kg/ (22.2%)

It will be imported in either rolls or sheets of varying lengths of 1.06 meter widths and thicknesses of 2.5 mm. You indicate that this material can be used in conditions up to 250 degrees centigrade, and that the product can be manually wrapped around the shaft of a pencil measuring 7 mm in diameter without fracturing.

You believe this material is classified in subheading 5903.90.2000, which covers “textile fabrics impregnated, coated, covered or laminated, with plastics,  of man-made fibers, over 70 percent by weight of rubber or plastics.”

Heading 5911 applies to:

(a) Textile products in the piece, cut to length or simply cut to rectangular (including square) shape, Â the following only:

(i) textile fabrics, felt and felt-lined woven fabrics, coated, covered or laminated with rubber, leather or other material, of a kind used for card clothing, and similar fabrics of a kind used for other technical purposes.

The material, because of its specific nature and use as a cushioning heat press pad in a pressing/laminating machine, is more specifically considered a textile product for technical use.

The applicable subheading for the Kinyo Board will be 5911.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for textile products and articles, for technical uses,  textile fabrics, felt and felt-lined woven fabrics, coated, covered or laminated with rubber, leather or other material, of a kind used for card clothing, and similar fabrics of a kind used for other technical uses other than printers’ rubberized blankets. The duty rate will be 5.6 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 George Barth at 212-637-7085.

Sincerely,

Robert B. Swierupski
Director,

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