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NY 814314

December 30, 1996

CLA-2-85:S:N:N1:108 814314


TARIFF NO.: 8529.90.9900

Ms. Neva Owens
Advanced Rubber Concepts, Inc.
P.O. Box 489
HWY. 77 South
Pauls Valley, Oklahoma 73075

RE: The tariff classification of keypads from Japan.

Dear Ms. Owens:

In your letter dated September 1, 1995, you requested a tariff classification ruling.

This item is a keypad used in the assembly of cellular telephones. The keypad is made of silicone, which you describe as a synthetic rubber. Note 4 (a) to Chapter 40 of the Harmonized Tariff Schedule of the United States requires that synthetic rubbers be unsaturated synthetic substances which can be irreversibly transformed by vulcanization with sulfur into non-thermoplastic substances which meet certain tests for elongation and recovery. Silicone is not an unsaturated substance which can be vulcanized with sulfur, and thus is not considered to be a rubber for tariff classification purposes. Instead, it is considered to be a plastics material.

The applicable subheading for the keypad will be 8529.90.9900, Harmonized Tariff Schedule of the United States (HTS), which provides for parts suitable for use solely or principally with the apparatus of headings 8525 to 8528: other: other: other. The rate of duty will be 4.7 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 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 Mario Dicerbo at 212-466-5672.


Roger J. Silvestri

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