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NY M82176




May 8, 2006

CLA-2-39:RR:NC:SP:221 M82176

CATEGORY: CLASSIFICATION

TARIFF NO.: 3919.90.5060

Ms. Stacy A. Hallon
Nippon Express USA, Inc.
8065 Tristar
Irving, TX 75063

RE: The tariff classification of “Riki II” blocking pads.

Dear Ms. Hallon:

In your letter dated April 11, 2006, on behalf of Miki Sangyo, you requested a tariff classification ruling.

Samples were provided with your letter. The Riki II blocking pads are oval pads made of cellular polyurethane measuring approximately 1 7/16 inches by 13/16 inch. The pads are used during the manufacture and assembly of super hydrophobic coated optical lenses to prevent slipping while the lenses are edged. The pads are flat and self-adhesive. You suggest classification in heading 3909, which provides for polyurethane in primary forms. Primary forms include pellets, powders and the like. The pads are finished products.

The applicable subheading for the Riki II blocking pads will be 3919.90.5060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics...other. The rate of duty will be 5.8 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. You did not state the country of origin. The rate of duty above is the rate applicable to this product when it is made in a country with which the United States has Normal Trade Relations.

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 Joan Mazzola at 646-733-3023.

Sincerely,

Robert B. Swierupski
Director,

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