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NY A86520

September 24, 1996
CLA-2-39:RR:NC:FC:238 A86520


TARIFF NO.: 3907.30.0000

Mr. Shaun Robertson
M.G. Chemicals
23 Racine Road
Etobicoke, Ontario, Canada M9W 2Z4

RE: The tariff classification of Encapsulating Epoxy Kit (Clear & Black) (Part A & Part B) from Canada

Dear Mr. Robertson:

In your letter dated May 28, 1996, resubmitted on July 19, 1996, you requested a tariff classification ruling.

The submitted sample consists of two commercially labeled retail containers, designated Part A and Part B. An analysis performed by the U.S Customs laboratory indicates that Part A is a clear, colorless liquid composed of a polymer (epoxide resin type), while Part B (a clear, viscous, amber liquid) is a mixture composed of a polyamide and a non-aromatic nitrogenous compound [hardener/curing agent for epoxide (i.e., Part A)]. With respect to the mix ratio, the directions state that 2 parts of epoxy resin (Part A) are to be mixed with 1 part of hardener (Part B) to form the finished product (i.e., cured epoxide resin). You indicate in your letter that Parts A & B are intended to be mixed together prior to use, and are put up for retail sale in kit form. The product is used for encapsulating and potting, in order to protect sensitive components and circuits from static discharge, impact, heat, shock, vibration, etc.

The applicable subheading for the subject kit will be 3907.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for: "Polyacetals, and other polyethers and epoxide resins, in primary forms; ... : Epoxide resins." The general rate of duty will be 6.1 percent ad valorem.

This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which is administered by the Environmental Protection Agency. You may contact them at 402 M Street, S.W., Washington, D.C. 20460, telephone number (202) 554-1404, or EPA Region II at (908) 321-6669.

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 Cornelius Reilly at 212-466-5770.


Roger J. Silvestri

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