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NY R02556

October 11, 2005

CLA-2-29:RR:NC:2:239 R02556


TARIFF NO.: 3824.90.9190

Ms. Shelley Vybiral
Lord Corporation
2000 W. Grandview Blvd.
Erie, PA 16509

RE: The tariff classification of Magneto-Rheological fluid, hydrocarbon based – Lord MRF-132AD, MRF-122-2ED; silicone based – Lord MRF-336AG; and water based MRF-241ES and MRF-240BS from China.

Dear Ms. Vybiral:

In your letter dated September 9, 2005, you requested a tariff classification ruling for the above products which you have stated are suspensions of micron-sized, magnetizable particles in a carrier fluid. Information submitted with your inquiry states that normally these fluids are free-flowing liquids having a consistency similar to that of motor oil. However, when a magnetic field is applied their rheology changes, virtually instantly, to a consistency similar to peanut butter.

The chemical breakdowns are as follows:

MRF-132AD (Hydrocarbon Based) - iron powder, molyvan 855, vanlube 7611M, synfluid 2.5, and nye reolube 737.

MRF-122-2ED (Hydrocarbon Based) - iron powder, molyvan 855, vanlube 7611M, uniflex DOS, synfluid 2.5, and nye reolube 737.

MRF-336AG (Silicone Based) - organosilicone fluid, iron powder, ferrite, and tegopren 5878.

MRF-241ES (Water Based) - deionized water, sodium nitrite, iron powder, prestone low tox, and laponite RDS.

MRF-240BS (Water Based) - deionized water, sodium nitrite, iron powder, sodium carboxymethyl, and ethylene glycol.

The applicable subheading for all the fluids will be 3824.90.9190, Harmonized Tariff Schedule of the United States (HTS), which provides for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: other. The rate of duty will be 5 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 Andrew Stone at 646-733-3032.


Robert B. Swierupski

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