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NY F84357

March 27, 2000

CLA-2-76:RR:NC:1:118 F84357


TARIFF NO.: 7607.20.5000

Ms. Barbara Dawley
Meeks & Sheppard
Attorneys at Law
1735 Post Road
Suite 4
Fairfield, CT 06430

RE: The tariff classification of aluminum foils from Belgium.

Dear Ms. Dawley:

In your letter dated March 20, 2000, you requested a tariff classification ruling on behalf of your client, Ethicon, Inc., a Johnson & Johnson company located in Somerville, NJ.

You have described your submitted samples as aluminum foils. The two grades of aluminum foil, designated as MS156-066 and MS156-067, will be imported in roles of various weights. Grade MS156-066 is produced by bonding polyurethane backing (PET film) to aluminum foil by means of an adhesive. The polyurethane backing reinforces the aluminum foil to facilitate its use as packing material. The foil is completed by coating the primary foil side with a heat sealant. The backing material is 0.48 mil in thickness (1 mil = 0.0254 mm) and the aluminum foil is 1.5 mils in thickness.

Grade MS156-067 is produced by first applying a thin coating of white pigment to a PET film. The PET film backing is coated with pigment so that the product information may be printed on the packaging material. The lacquered PET film is then bonded to aluminum foil using adhesive. The final step involves coating the primary aluminum side with a heat sealant. The aluminum foil has a thickness of 1.5 mils.

Each grade of foil uses aluminum alloys having a purity content of over 98%, and the aluminum content of the finished foil predominates by weight over the PET film. Each of these foils will be used to manufacture packaging material for sutures. The PET is utilized to add strength to the foil in order to facilitate packaging of the sutures.

The applicable subheading for both grades of the aluminum foil will be 7607.20.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2mm: backed: other. The duty rate 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 this 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 Kathy Campanelli at 212-637-7025.


Robert B. Swierupski

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