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NY 893453

January 7, 1994

CLA-2-39:S:N:N6:221 893453


TARIFF NO.: 3920.99.2000

Mr. Steve Liptak
Inter-Maritime Forwarding Co. Inc.
156 William Street
New York, NY 10038

RE: The tariff classification of split polyvinyl alcohol film from Japan.

Dear Mr. Liptak:

In your letter dated December 2, 1993, on behalf of Nichimen America Inc., you requested a tariff classification ruling.

The product is identified as "Bell Solve" KG 30 and KG 60 polyvinyl alcohol (PVA) film. It is made from film which is mechanically slit into a network of interconnected fibrils. One layer of film is laid on top of and perpendicular to another, and the two are bonded together. Though the material gives an appearance of being a textile fabric, it consists of a single plastics unit, with no individual fibers, filaments, or strips contributing to its existence. It is used as a water soluble substrate in the manufacture of Schiffli embroidery. The film will be imported in widths of 45, 57 or 59 inches, in lengths of 580 meters, packaged on rolls.

The applicable subheading for the split PVA film will be 3920.99.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for other film, strip and sheets, noncellular and not reinforced, laminated, supported, or similarly combined with other materials, of other plastics, flexible, other. The rate of duty will be 4.2 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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