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NY A86084

August 30, 1996

CLA-2-35:RR:NC:FC:236 A86084


TARIFF NO.: 3506.10.5000

Mr. Andrew M. Carreno
Carreno & Neil Shipping Co.,Inc.
1A Colony Road
Jersey City, NJ 07305

RE: The tariff classification of Mega-Bond Epoxy Pump System (Cat.No. 8401) from Germany

Dear Mr. Carreno:

In your letter dated August 1, 1996, on behalf of your client, Power Rawl/Rawlpug Co. of New Rochelle, NY, you requested a tariff classification ruling.

The Mega-Bond Epoxy Pump System described in literature submitted with your request consists of a sealed plastic cylindrical pump, approximately 22cm in length and 5 cm in diameter, equipped with a 26 cm plastic plunger that extends 24 cm beyond the end of the cylinder when fully drawn. The cylinder is separated into two chambers by a plastic disc and holds an epoxy resin in one chamber and an amine curing agent in the other. The plunger is designed to break the seal between the two chamber and mix their contents, when fully extended and pumped at least 25 full strokes. Upon curing for a specified time, the mixture forms an adhesive. After removing the handle from the extended plunger, the pump is inserted into a caulking gun and is ready to dispense the adhesive contained therein.

You indicated that the system will be made in Germany and that the two chemicals used in the system will be made in the United States and exported to Germany where they are to be introduced into the chambers of the pump in exactly the same state as exported, not advanced in value, or improved in condition, and will not lose their physical identity. Upon use by the ultimate U.S. consumer, only then will the two chemicals mix to form an adhesive.

The applicable subheading for the Mega-Bond Epoxy Pump System will be 3506.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for prepared glues and other prepared adhesives, not elsewhere specified or included; products suitable for use as glues or adhesives, not exceeding a net weight of 1 kg: Products suitable for use as glues or adhesives, put up for retail sale as glues or adhesives, not exceeding a net weight of 1 kg: Other. The rate of duty will be 2.1 percent ad valorem.

Based on the information provided, the two chemical components of this system qualify for treatment under subheading 9802.00.80, HTS, as products of the United States. With submission of the appropriate documentation at entry, duty will be assessed upon the full value of the imported article, less the cost or value of such products of the United States.

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 V. Gualario at 212-466-5744.


Roger J. Silvestri

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