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NY K84271




June 3, 2004

CLA-2-71:RR:NC:N1:113 K84271

CATEGORY: CLASSIFICATION

TARIFF NO.: 7115.90.4000

Ms. Aasha Desloge
Best Buy Purchasing LLC
7601 Penn Ave. S, Bldg D4
Richfield, MN 55423

RE: The tariff classification of thermal compound from China.

Dear Mr. Desloge:

In your letter dated March 9, 2004, you requested a ruling on tariff classification.

The sample you provided is a thermal compound, item DX-STC100. The compound acts as a heat sink when spread across the CPU die of a computer. A laboratory report indicates that the compound is made essentially of granulated silver with some zinc, and silicone. It will be packaged with a spreader card for use in application.

The applicable subheading for this product will be 7115.90.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of precious metal, other, other, of silver. The general rate of duty will be 3 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.). 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 James Smyth at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,

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