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NY N005232

January 26, 2007



TARIFF NO.: 3926.90.9880

Mr. Norman Harris III
Nippon Express USA, Inc.
2233 East Grand Avenue
El Segundo, CA 90245

RE: The tariff classification of heat protectors from Japan

Dear Mr. Harris:

In your letter dated November 22, 2006, on behalf of Hisatake Tetsu Muraoka, you requested a tariff classification ruling.

The sample submitted with your letter is identified as a “gekihie” thermal conductive coolant. It is imported as a package of two small, flat squares with rounded corners. The samples measure 1 11/16 inches by 1 11/16 inches by 1/16 inch. The squares are of laminated construction. One layer is aluminum and is said to act as a heat reflector. The second layer is silicone plastic and is said to act as a thermal conductor. The squares are designed to be attached to products that get hot during use, such as laptop computers, DVD players and game consoles. The silicone has a slight tackiness that allows it to adhere lightly to the laptop or other device. The silicone conducts the heat away from the equipment. According to the breakdowns submitted with your request, the weights of the aluminum layer and the silicone layer are identical, and the silicone accounts for 80 percent of the value. The essential character is imparted by the silicone material.

The applicable subheading for the thermal conductive squares will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Joan Mazzola at 646-733-3023.


Robert B. Swierupski

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