CLA-2-90:S:N:N3:114 807234

Mr. Kenneth N. Wolf
3293 Harbor Point Road
Baldwin Harbor, N. Y. 11510

RE: The tariff classification of acrylic filters, reflectors and light guide panels from Japan

Dear Mr. Wolf:

In your letter dated December 16, 1994, on behalf of Astra Products, Inc., you requested a tariff classification ruling. The products for involved are the Clarex DR-I Diffusion Reflector, the Clarex DR-II Transmission Diffuse Reflector, the Clarex DR-IIIC Diffusion Filter, the Clarex DR-IIICV Color Diffusion filter, the Clarex Light Guide Panel and the Clarex Non- Glare Filter.

The Clarex DR-I Diffusion Reflector is used as a backlight filter/reflector for Liquid Crystal Displays (LCDs). Its most typical application is in LCD watches where it also acts a light guide. The acrylic sheet is manufactured in an initial size of approximately 15 3/4 in. by 25 1/2 in (400 x 550 mm). An aluminum layer and a black back coating is applied to the acrylic panel. The diffusion reflector is cut and/or routed to the customer's specifications for assembly into an LCD display.

The Clarex DR-II Transmission Diffuse Reflector is used as a component of a back light unit for an LCD. It reflects light from LCDs during daylight and diffuses transmitted light from an internal lamp at night. The reflector is composed of an acrylic sheet which is coated and laminated with a reflection layer underneath the acrylic and a diffusion layer under the reflection layer. The reflector is available in 0.5 mm thickness and is manufactured in sizes according to a customer's specifications for direct assembly into an LCD unit. The Clarex DR-IIIC Diffusion Filter and Clarex DR-IIICV Colored Diffusion Filter feature high light transmission, diffusion

and high color temperature. The Clarex DR-IIIC Diffusion Filter is manufactured in 400 x 550 mm size and is cut and/or routed to a customer's specifications. The thickness is from 0.3 mm to 2.0 mm. The Clarex DR-IIICV Color Diffusion Filter is manufactured in a manner similar to the DR-IIIC Filter. The filters are available in red, green, blue, yellow, orange and other colors to permit a variety of colored LCDs. The filter is manufactured in 400 x 550 mm size which is then cut and/or routed to a customer's specifications. Its thickness is 0.5 mm.

The Clarex Light Guide Panel is used as a light guide for the back lights of LCDs. These are composed of acrylic with an added light scattering compound and are laminated or coated with a non- acrylic reflection layer on the bottom surface. These are cut and/or routed a customer's specifications and are available in thicknesses ranging from 0.5 mm to 5.0 mm.

The Clarex Non-Glare Sheet is used for the surface panel for electronic displays such as LCDs, CRTs, PDPs, ELs, VFDs and LEDs. The Clarex Non-Glare Sheet has high transmittance and enhances the contrast between the characters and background and the anti- reflection surfaces. It is available in thicknesses ranging from .5 mm to 5.0 mm. It is manufactured in the 400 x 550 mm size and then cut and/or routed to the customer's specifications. According to your letter, the above products will be imported in a finished condition ready for sale to the customer. The applicable subheading for the Clarex DR-I Diffusion Reflector, the Clarex DR-II Transmissive Diffuse Reflector, Clarex DR-IIIC Diffusion Filter, Clarex DR-IIICV Color Diffusion Filter, Clarex Light Guide Panel, and Clarex Non-Glare Filter will be 9001.90.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other optical elements, of any material, unmounted, other than optical elements of glass not optically worked, other, other. The rate of duty will be 7.3 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport