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NY L86542

October 31, 2005

CLA-2-68:RR:NC1:126: L86542


TARIFF NO.: 6805.30.1000

Mr. Dwayne Knight
Arc Abrasives
85 Marybill Drive
Troy, Ohio 45373

RE: The tariff classification and country of origin of abrasive discs manufactured in Italy and China

Dear Mr. Knight:

In your letter, dated July 18, 2005, you requested a ruling regarding tariff classification and regarding the correct country of origin for two abrasive disc shaped articles, items 53943 (blue) and 59342 (red).

Samples of the articles were submitted with your ruling request.

These samples were sent to our Customs laboratory for analysis. The laboratory has now completed its analysis of the products.

You stated that surface conditioning material (consisting of textile material coated with abrasive grain) is manufactured in Italy. This material is cut and placed on metal or plastic disc retainers in China.

Lab analysis of the products indicated the following. A plastic or metal retainer is attached to one side of each of these articles. The side with the retainer includes a cross-woven mesh of fibers. Non-woven fiber material is attached to the other side of the disc. An aluminum oxide (corundum) abrasive is attached to the non-woven material with an organic resin.

The applicable subheading for the abrasive discs will be 6805.30.1000 HTS, which provides for natural or artificial abrasive powder or grain, on a base of textile material, of paper, of paperboard or of other materials, whether or not cut to shape or sewn or otherwise made up: on a base of other materials: articles wholly or party coated with abrasives, in the form of sheets, strips, disks, belts of similar forms. The rate of duty will be free.

Since the surface conditioning material is manufactured in Italy, the country of origin of the merchandise is Italy.

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 Jacob Bunin at 646-733-3027.


Robert B. Swierupski

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