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NY N009979

September 21, 2007



TARIFF NO.: 3403.99.0000

John M. Peterson
Neville Peterson LLP
17 State Street -19th Floor
New York, New York 10004

RE: The tariff classification of Alpha-Coat Synthetic Resin Lubricant from Japan

Dear Mr. Peterson:

In your letter dated April 17, 2007 you requested a tariff classification ruling on behalf of your client Nagase America Corporation.

Our laboratory analyzed the sample that you had submitted. Your sample did not contain any petroleum oils.

You state in your literature that the Alpha-Coat Synthetic Resin Lubricant provides squeak elimination, controlled torque, antiseizing properties, chemical resistance and corrosion resistance. Based on your information and the exhibits you provided this product is not used for the treatment of textiles or like material.

The applicable subheading for the Alpha-Coat Synthetic Resin Lubricant will be 3403.99.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Lubricating preparations (including cutting-oil preparations, bolt or nut release preparations, antirust or anticorrosion preparations and mold release preparations, based on lubricants) and preparations of a kind used for the oil or grease treatment of textile materials, leather, furskins or other materials, but excluding preparations containing, as basic constituents, 70 percent or more by weight of petroleum oils or oils obtained from bituminous minerals: Other: Other. The rate of duty will be 6.5 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 Debra Wholey at 646-733-3034.


Robert B. Swierupski

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