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NY A87521

October 15, 1996

TARIFF NO.: 5911.10.2000

Ms. Shirley E. Wrench
Union Transport Corp.
114 Southfield Parkway, Suite 170
Forest Park, GA 30050

RE: The tariff classification of rubberized textile fabric of a kind used for card clothing, from the United Kingdom and Belgium.

Dear Ms. Wrench:
In your letter dated August 27, 1996, on behalf of Ashworths Card Clothing, Inc., Greenville, S.C., you requested a tariff classification ruling.

You state that foundations are manufactured in the U.K. by Horsfall & Bickham and by Tiscar in Belgium.

No samples were furnished or specifications of how shipped, respective weights or thicknesses, just a brochure of certain types of card clothing.

Your letter mentions that Ashworth is a manufacturer of flexible card clothing used on textile carding machinery and other manufacturing processes such as, screen printing, scratching designs on bricks, embossing paper products, machines producing paint roller brushes and paint brush tapering, designs in ceiling tiles, assorted wire brush pads for the brush industry and similar products. This letter will address only the production of the material used to make card clothing foundation for textile machinery, as this is the major portion of Ashworth's business indicated in a phone conversation with Mr. Jeff Smith, of your office, and George Barth .

The card clothing foundation is developed by textile material (cotton, linen, wool-linen or felt) being processed through machinery where either synthetic or natural rubber adhesive is being applied followed by the same process over and over as the thickness of the foundation (number of textile plies) has been achieved. The make-up of the foundation, how many plies of cotton, linen, etc., are determined by the end application of Ashworth. You also indicate some foundations require a rubber face. This is achieved, you say, in a long process where a thin layer of rubber is applied to a single ply of cotton and built up with multiple passes, sometimes more than 60, till the desired thickness is achieved. This one ply of cotton with the rubber face is then glued on top of the previous built-up foundation material.

In your letter you write that the textile fabrics may come from the U.K., Belgium, India or Spain with the rubber mainly from Malaysia. Also, that you have had ongoing shipments through a number of Southern ports, but never any detained shipments questioning the classification of the merchandise, though there have been occasional questions on the reporting units with the census copy. We are treating this letter as prospective for future shipments and again mentioning we are only addressing the classification of foundation material of a kind used for card clothing.

The applicable subheading for the product will be subheading 5911.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for textile fabrics ... coated, covered or laminated with rubber, ... of a kind used for card clothing... The rate of duty is 6.8 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations. 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. Sincerely, Roger J. Silvestri Director National Commodity Specialist Division

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