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April 13, 1999

CLA-2-48:RR:NC:2:234 E80303


TARIFF NO.: 4818.40.2000

Mr. Robert J. Leo
Meeks & Sheppard, Attorneys at Law
330 Madison Avenue (39th Floor)
New York, N.Y. 10017

RE: The classification of “feminine sanitary pad” from Trinidad & Tobago.

Dear Mr. Leo:

This is in response to your letter dated April 2, 1999, on behalf of your client, Johnson & Johnson Consumer Products Co., your file: JJCP-010, requesting a ruling as to the tariff classification of feminine sanitary pads from Trinidad & Tobago. Samples were submitted, which will be retained for reference.

Your letter requested confidential treatment for certain sensitive business information, but in a telephone conversation with a member of my staff, on April 8, 1999, you abandoned that aspect of your request.

The articles concerned are designated “Stayfree(R) Regular Maxi” sanitary pads. The purpose of the pad is to be worn by a woman inside the panty to absorb any menstrual discharges. Each imported pad is composed of a fibrillated wood pulp absorbent insert, a polyethylene moisture barrier, a polypropylene cover, hot melt adhesive, and a strip of silicone coated paper.

The product consists preponderantly by weight of the fibrillated wood pulp, and it is the wood pulp which fulfills the primary function of the product, which is to absorb any fluid discharge.

The applicable subheading for the “Stayfree (R) Regular Maxi” sanitary pads will be 4818.40.2000, Harmonized Tariff Schedule of the U. S. (HTS), which provides for: Sanitary napkins and tampons, diapers and diaper liners and similar sanitary articles: Of paper pulp. The rate of duty is Free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter 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 this ruling, contact National Import Specialist Carl Abramowitz, at (212) 637-7060. Sincerely,

Robert B. Swierupski

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