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September 5, 1999

CLA-2-35:RR:NC:2:237 E85576


TARIFF NO.: 3506.10.5000

Mr. Steven P. Sonnenberg
Sonnenberg & Anderson
200 South Wacker Drive
Chicago, Illinois 60606

RE: The tariff classification of Tape’n’Roller from Japan.

Dear Mr. Sonnenberg:

In your letter dated August 3, 1999, on behalf of Kokuyo U.S.A., you requested a tariff classification ruling.

Two samples of Tape’n’Roller were submitted with your letter. The samples are plastic dispensers containing either permanent or removable double-faced adhesive strip on a conveyer of long strip silicon coated glassine paper. The adhesive strip is 10mm wide and 10m long, segmented 3.5mm by 10mm. The adhesive is applied by rolling the dispenser tip against the surface of the item to be adhered then breaking contact at the desired length.

You suggest classification in heading 3919, HTS, which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes of plastics. Heading 3919 provides for strips of plastics coated with adhesive. The instant merchandise consists of adhesive in strip form. There is no discrete strip of plastics in the samples submitted with your request.

The applicable subheading for the Tape’n’Roller will be 3506.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for prepared glues and other prepared adhesives, not elsewhere specified or included; products suitable for use as glues or adhesives, put up for sale as glues or adhesives, not exceeding a net weight of 1 kg: products suitable for use as glues or adhesives, put up for retail sale as glues or adhesives, not exceeding a net weight of 1 kg:other. The rate of duty will be 2.1 percent ad valorem.

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 Frank Cantone at 212-637-7018.


Robert B. Swierupski

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