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NY 815631

November 9, 1995

CLA-2-56:R:N3:350 815631


TARIFF NO.: 5601.21.0010; 5602.10.9090

Mr. James V. Perez Jr.
Camel Services Inc.
P.O. Box 3252
1907 Aduanales
Laredo, TX 78044-3252

RE: The tariff classification of two needleloom felts and four wadding materials for underlay pad use in the automotive industry, from Mexico.

Dear Mr. Perez:

In your letter dated October 2, 1995, on behalf of Fieltros y Cobertores, S.A. de C.V. of Teziutlan Sur 83 Col. La Paz in Puebla, Mexico, you requested a tariff classification ruling.

Six representative samples were submitted. All six of these materials are for ultimate use as automotive insulation and sound deadner parts in automobiles. Since they will be imported as roll goods to be further cut, shaped and manufactured after importation, they are not eligible for consideration as automobile parts in the tariff as you suggest. The first two items, identified as styles (1) "Nonwoven Needlepunch White Felt Prin 003" and (2) "Nonwoven Needlepunch Multicolor Pad Prin 002", both consist of standard 100% polyester needlepunched felt fabrics which are composed predominately of synthetic man-made fibers for product 003 and a varying blend of 85% recycled man-made fibers and 15% recycled cotton fibers for product 002.

The third item, style (3) "Nonwoven Resinated Felt Trifelt Prin 001", consists of a wadding material which consists of a flexible, spongy, high-bulk sheet, of even thickness (about 1/2"), the fibers of which are readily separable. This particular material appears to consist of a lower grade of material composed principally of waste obtained form carded or garnetted fibers. The text of your letter indicates that the material is principally composed of cotton fibers. It also mentions the application of a synthetic resin which is not readily identifiable in the material. That may be because the resin was dispersed in the form of a powder that does not really agglutinate the fibers.

The fourth, fifth and sixth items, styles (4) "Nonwoven Resinated Semicured Felt-Trifelt SC Aut501-Aut502-Aut503-Aut-504", (5) "Nonwoven Resinated Semicured Felt-Trifelt SC Aut-501-Aut502-Aut503-Aut504", and (6) "Nonwoven Resinated Semicured Felt-Trifelt SC Aut501-Aut502-Aut503-Aut504", are similar in construction and composition to the third item, except that there is mention of the fact that these three materials are "semicured", as opposed to the third material. Products 4-6 list a varying blend range of from 55 to 70% recycled cotton fibers, 10 to 13% recycled synthetic fibers and 17 to 25% synthetic resin. These materials, which are also composed predominately of cotton, measure between approximately 1/2" and 1" in overall thickness.

The applicable tariff provision for the first two items will be 5602.10.9090, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for ... needleloom felt and stitch-bonded fiber fabrics, of other than wool or fine animal hair. The general rate of duty will be 12.3 percent ad valorem. The remaining four items (3, 4, 5 and 6), fall in item 5601.21.0010, HTS, which provides for ... wadding, in the piece, of cotton. The general rate of duty is 6.8 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 212-466-5884.


Roger J. Silvestri

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