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April 30, 1999

CLA-2-56:RR:NC:TA:350 C84047


TARIFF NO.: 5603.94.3000

Mr. Alwin Heil
Euro-Composites corporation
Culpeper County Industrial Airpark
13213 Airpark Drive
Elwood, Virginia 22718-1703

RE: The tariff classification of multi layers of partial laminated sheets of Nomex® aramid “paper” for making honeycomb blocks, from Luxembourg.

Dear Mr. Heil:

In your letter dated January 29, 1998, you ask for the classification of sheets or blocks of laminated Nomex® “paper”, which is the precursor of aramid fiber honeycomb. A sample each of the nonwoven fabric, a sheet after the application of the epoxy resin and the sheets laminated together, which represents the merchandise to be imported, were submitted. We apologize for the delay in responding to your inquiry.

It has been established for sometime (HQ letter 076861 Oct. 31, 1986) that the referred to Nomex is a nonwoven material of staple length fibers made in a wet lay process. It is textile in nature. The particular sample of the nonwoven fabric submitted has an approximate weight of 43 g/m², is about 0.064 mm thick and falls under HTS subheading 5603.92. Rolls of this material, 36 inches wide, measuring 8,000 meters long, with some rolls being 10,000 meters, are sent to Luxembourg. Some rolls will be 24 inches wide.

The nonwoven material is cut into sheets of varying lengths, depending on the desired dimension of end product, which may range in length from 59 inches (1520 mm) to 103 inches (2624 mm). The width will remain the same, i.e. 36 inches, only single straight cut lengths are cut from the roll.

The sheets are printed or coated with thin, 1.5 to 2.5 mm wide, parallel lines of an epoxy resin spaced every 7.5 to 10 mm across the width of the material. The resin serves as a node bond adhesive for spot lamination.

The cut sheets are stacked up to a desired thickness and are spot laminated by compression and temperature in a press. The product or unit talked about (item to be imported) in a phone conversation with Mr. Heil will be a sheet or block measuring 64 by 36 by 3.5 inches. Sheets of other dimensions may also be manufactured. This sheet or block, after importation, will be expanded ( the 3.5" thickness will be extended a number of feet) to make the honeycomb structure block. It will be impregnated with a phenolic resin and stabilized in a curing oven. The stabilized honeycomb material becomes the light weight core material for sandwich structures used in the aircraft industry.

The “block” of the built up layers of the nonwoven fabric is not considered to be a made up textile product, following Section XI note 7(e), but remains as material in the piece.

You request consideration for subheading 9802.00.80, i.e., articles assembled abroad with components produced in the United States. Since the roll material is cut to length in a single cut and has not lost its identity in the laminating process, it appears, if all conditions are met, the goods would qualify for consideration under this subheading. However, we note that goods entering under the classification given below are, as of 1999, unconditionally Free of duty. The applicable subheading for the material will be 5603.94.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for nonwovens, whether or not impregnated, coated, covered or laminated, of other than filaments, weighing more than 150 g/m², ... laminated fabrics. The rate of duty will be Free.

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 George Barth at 212-637-7085.


Robert B. Swierupski

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