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NY L84948

June 9, 2005

CLA-2-37:RR:NC:SP:236 L84948


TARIFF NO.: 3702.39.0000

Ms. Lucy Richardson
Sony Electronics Inc.
1 Sony Drive
Park Ridge, New Jersey 07656-8003

RE: The tariff classification of photo identification ribbons in rolls from Japan

Dear Ms. Richardson:

In your letter dated May 12, 2005 you requested a tariff classification ruling on behalf of Sony Chemicals Corporation of America.

In your descriptive literature you state that the photo identification ribbons will be imported in rolls and used in dye diffusion thermal transfer printers to create security products such as photo ID badges, safe child badges, licenses and entry cards. You state that the five models of photo identification ribbons consist of a base of polyethylene terephthalate (PET) film that has been coated with three layers of resins, waxes and dye colorants. Your literature states that the dyes are considered photosensitive dyes since they react to the application of heat by a printer head and cannot be transferred from the film onto the media by mechanical impact. All five models of imported photo identification ribbon are approximately the same size with widths ranging from 60 mm to 66 mm wide and lengths from 228,000 mm to 239,400 mm long.

The five models of photo identification ribbon are the following:

YMCK 500 print #17810519
YMCKK 400 print #17800309
YMCKOK 350 print #17800295
YMCKO 400 print #17800284
BO 500 print #17810531

The two samples that you submitted are being retained for training purposes.

The applicable subheading for the photo identification ribbons will be 3702.39.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles; instant print film in rolls, sensitized, unexposed: Other film, without perforations, of a width not exceeding 105 mm: Other. The rate of duty will be 3.7 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 Debra Wholey at 646-733- 3034.


Robert B. Swierupski

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