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NY G82075

September 25, 2000

CLA-2-30:RR:NC:2:238 G82075


TARIFF NO.: 3005.90.5090

Mr. Richard S. Wang
Symtex Healthcare Corporation
783 Pinefalls Avenue
Walnut, CA 91789

RE: The tariff classification of non-sterile disposable cotton dental rolls, from China

Dear Mr. Wang:

In your letter dated September 11, 2000, you requested a tariff classification ruling.

The submitted samples consist of non-sterile, disposable, cotton, dental rolls, each measuring ~ 1½” x ”, and a paperboard container in which, you state, the rolls will be put up (2000 per container), in their condition as imported. The container bears the country of origin marking: “PRODUCT OF CHINA.” The container also bears the following marking: “MED-TEX, COTTON ROLLS, 2000 ROLLS, NO. 2 MEDIUM, 1½” x ”, NON-STERILE, REORDER # DR1-1538.”

You include the following statement in your letter: “[W]e confirm again that the imported merchandise consists of cotton rolls put up (in) boxes containing 2000 rolls/Box (and) will ONLY reach the end users intact in these boxes. There (They) will NOT not be repackaged into any (other) types of containers at all prior to reaching the end-users.” Accordingly, pursuant to your certification and the Explanatory Notes to heading 3005, HTS, we are of the opinion that the subject merchandise is exclusively intended for sale – directly, without repacking – to users for medical, surgical, dental or veterinary purposes.

The applicable subheading for the subject cotton rolls will be 3005.90.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for "{W]adding, gauze, bandages and similar articles , impregnated or coated with pharmaceutical substances or put up in forms or packings for retail sale for medical, surgical, dental or veterinary purposes: Other: Other: Other." 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 Harvey Kuperstein at 212-637-7068.


Robert B. Swierupski

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