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NY 860062

Mar 1 1991

CLA-2-32:S:N:N1:236 860062


TARIFF NO.: 3215.90.5000 3208.90.0000

Dr. Neil S. Fox
402-B North Curry Street
Carson City, Nevada 89703

RE: The tariff classification of PSR-4000 SOLDER MASK INK and PSR-4000C SOLDER MASK INK from Japan

Dear Dr. Fox:

In your letter dated November 26, 1990 you requested a tariff classification ruling.

The prospective import, PSR-4000 Solder Mask Ink is a two part ink system imported as a one kg. set consisting 750 grams of ink (dye or pigment, epoxy/acrylate binder, solvent, and additives) and 300 grams of CA-40 ink hardener.

The soldermasks are negative-working inks that are resistant to the soldering process. The mask is silk screened onto a circuit board and after curing, the board is dipped into solder. The solder adheres to the non inked surfaces thus forming a positive image of the circuit. It is also claimed that this product is used to produce lettering and other images on the reverse side of the circuit board.

The importer plans to import various colors including green, blue, red, black, and colorless. The colorless will be identified as PSR-4000C Solder Mask Ink. In our opinion, the colorless drying to a transparent or translucent hard film would be a varnish.

The applicable subheading for the (two part system), "PSR- 4000 Solder Mask Ink" will be 3215.90.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for printing ink, writing or drawing ink and other inks, whether or not concentrated or solid, other. The rate of duty will be 1.8 percent ad valorem.

The applicable HTS subheading for the "PSR4000C Solder Mask Ink" (colorless) will be 3208.90.0000, which provides for other paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a nonaqueous medium.. The rate of duty will be 3.2 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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