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NY F80920





June 26, 2000

CLA-2-56:RR:NC:TA:350 F80920

CATEGORY: CLASSIFICATION

Ms. Michelle Everitt
Beijing Trade Exchange, Inc.
701 East Street, SE
Washington, DC 20003

RE: The tariff classification of a nylon rectangular scrubbing pad, from China.

Dear Ms. Everitt:

In your initial letter dated November 10th (NY 80067) and follow up letter of December 14th, 1999, you requested a classification ruling.

The instant sample, identified as scrubbing pad Product #1, consists of a nylon scrubbing pad which is rectangular in configuration and measures approximately 6" x 6" x 3/8". Your initial request was returned because we asked for additional information on the scrubbing pad, such as its material composition, whether the pad was coated or impregnated with an abrasive powder or grain, and the identity of such coating substance. Your resubmitted letter of December 14, stated that “the product is a non-coated, non-impregnated nylon rectangular scrubbing pad. There is not a synthetic chemical or a naturally occurring mineral used in the manufacturing of this product. This fabric is made of short staple fibers. The weight of this finished material per square yard is 30 oz per square yard.”

However, from visual examination of the sample submitted and, noting the material’s tactile qualities, the sample was submitted to our laboratory for analysis. The Lab reports that the material is composed of synthetic staple fibers, some type of coarse/gritty material and a plastic binder. There was a 50% (non-textile) ash content that consisted of various inorganic compounds, essentially those of titanium, aluminum, iron, nickel and zirconium. There may be an abrasive compound involved, but we would need precise chemical or geologic names of the compounds as mentioned in our returning letter of December 3, 1999 (copy attached).

Because of the size of the sample and equipment and time constraints, the Lab was not able to identify, with certainty, the actual make up of the scrubber pad. Accordingly, we will not be able to respond to this inquiry and provide you with a definitive tariff classification without full and detailed manufacturing specifications, which provides a complete list of all ingredients incorporated into this product.

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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