• HQ 965711
• Jul 24, 2002

• Type : Classification • HTSUS : 6307.90.9889
•  Revoked by:   H283468     Related:   963488; D82853   

CLA-2 RR:CR:TE 965711 jsj

Ms. Estelle Lee
President, TL Care
P.O. Box 77087
San Francisco, California
94107

Re: Nursing Pads; Breast Pads; Paper Absorbent Component; Textile Wadding Absorbent Component; Woven Textile Fabric Absorbent Component; Nonwoven Textile Fabric, But Not Wadding Absorbent Component; General Rules of Interpretation 1 and 3(b); Essential Character; Headings 4818, 5601 and 6307, HTSUS; Not Clothing Accessories, Heading 6217, HTSUS; Woven Cotton Absorbent Component; Subheading 6307.90.9889, HTSUSA.

Dear Ms. Lee:

The purpose of this correspondence is to respond to your request dated April 25, 2002. The correspondence in issue requested a binding classification ruling of the merchandise described as a “nursing pad.”

This ruling is being issued subsequent to the following: (1) A review of your submission dated April 25, 2002; and (2) An examination of the sample that accompanied your ruling request.

FACTS

The article in issue, identified as a nursing pad, is designed to be placed in the brassiere of nursing mothers to absorb excess milk. It is circular or slightly conical in shape and measures five (5) inches in diameter. The nursing pad is composed entirely of four (4) layers of 100 percent woven cotton fabric stated to be flannel. No other materials form a part of this article. The circumference is sewn.

This merchandise is also commonly referred to as “breast pads.” The Customs Service, for convenience purposes, will refer to this item as a nursing pad.

The Customs Service is advised that the country of manufacture is China.

ISSUE

What is the classification, pursuant to the Harmonized Tariff Schedule of the United States Annotated, of the above-described nursing pad composed entirely of woven cotton fabric ?

LAW AND ANALYSIS

The federal agency responsible for initially interpreting and applying the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) is the U.S. Customs Service. The Customs Service, in accordance with its legislative mandate, classifies imported merchandise pursuant to the General Rules of Interpretation (GRI) and the Additional U.S. Rules of Interpretation.

General Rule of Interpretation 1 provides, in part, that classification decisions are to be “determined according to the terms of the headings and any relative section or chapter notes.” General Rule of Interpretation 1. General Rule of Interpretation 1 further states that merchandise which cannot be classified in accordance with the dictates of GRI 1 should be classified pursuant to the other General Rules of Interpretation, provided the HTSUSA chapter headings or notes do not require otherwise. According to the Explanatory Notes (EN), the phrase in GRI 1, “provided such headings or notes do not otherwise require,” is intended to “make it quite clear that the terms of the headings and any relative Section or Chapter Notes are paramount.” General Rules for the Interpretation of the Harmonized System, Rule 1, Explanatory Note (V).

The Explanatory Notes constitute the official interpretation of the Harmonized System at the international level. See Joint Explanatory Statement supra note 2, at 549. The Explanatory Notes, although neither legally binding nor dispositive of classification issues, do provide commentary on the scope of each heading of the HTSUS. The EN’s are generally indicative of the proper interpretation of the headings. See T.D. 89-80, 54 Fed. Reg. 35127-28 (Aug. 23, 1989); Lonza, Inc. v. United States, 46 F. 3rd 1098, 1109 (Fed. Cir. 1995).

The Customs Service, observing the dictates of GRI 1, to classify merchandise according to the terms of the headings and the section and chapter notes, has encountered significant difficulty in the classification of nursing pads. Nursing pads, as previously explained, are items used by nursing mothers to absorb excess breast milk during lactation. Nursing pads may be used for other purposes, but it is Customs conclusion that any use of nursing pads other than by nursing mothers to absorb excess milk is fugitive.

The difficulty encountered by Customs in classifying this merchandise stems from two facts: (1) Nursing pads are not designated eo nomine in the tariff schedule; and (2) The manufacturers of nursing pads utilize different materials, primarily different absorbent material, to construct their products. Customs commenced the classification of this merchandise with this understanding.

Customs survey of nursing pads indicates that they are manufactured utilizing primarily four types of absorbent material: (1) Paper and/or paper pulp; (2) Textile wadding; (3) Woven textile fabrics; and (4) Nonwoven textile fabrics that are not wadding. It is not Customs intention to suggest that this list is exclusive. Other absorbent materials may be used in the manufacture of nursing pads either presently or in the future. The four primary types of absorbent material addressed above, for the purposes of this ruling letter, are not in composition with any type of super absorbent chemical compound.

Since the tariff schedule does not designate nursing pads, eo nomine, that is by name, in any of the headings, Customs has determined that it is not possible to classify all nursing pads in a single heading. Failing to confirm a single heading into which all nursing pads may be properly classified, Customs re-examined the GRI’s, gave careful thought to the ruling requests and protests currently pending in the Office of Regulations and Rulings and reviewed the classification history of this line of merchandise. The decision was made, pursuant to the requirements of the GRI’s, to classify each article on its own merits.

The Customs Service, pursuant to the principles of “informed compliance” and “shared responsibilities” set forth in the Customs Modernization Act, has determined that in order for the trade community to understand Customs reasoning, it is important to address in this ruling letter Customs thought process with regards to the classification of nursing pads. It is Customs judgment because of the different ways in which different types of nursing pads are manufactured that providing comprehensive analysis of the classification of the different types of nursing pads will result in a more uniform and correct classification of this merchandise.

Simply addressing TL Care’s nursing pad would meet Customs legal obligation, but that would only inform Customs field personnel and the trade of the classification of one type of nursing pad. Only a complete and thorough discussion of the classification of the different types of nursing pads can result in the uniformity sought by Customs and the accurate classification of merchandise required of the trade.

The Customs Service will initially provide analysis of the headings that the agency has concluded are relevant to the classification of nursing pads. This ruling letter will conclude with the classification of the TL Care nursing pad.

It is the understanding of the Customs Service, as previously stated, that there are four primary types of nursing pads based on absorbent properties. The primary types of nursing pads include those with the following types of absorbent material: (1) Paper; (2) Textile wadding; (3) Woven textile fabrics; and (4) Nonwoven textile fabrics that are not wadding. Customs will address the classification, at the heading level, of nursing pads with each of these absorbent materials.

It is important to note that nursing pads are generally not composed entirely of the same material that provides the nursing pad with its absorbent capability. Although Customs focus, as will be addressed subsequently, will be on the material or substance that provides a nursing pad with its absorbent capability, proper application of the GRI’s mandate that Customs not ignore the other materials or substances which make-up a particular style of nursing pads.

Nursing Pads of Heading 4818

NURSING PADS COMPOSED ENTIRELY OF MATERIALS ENUMERATED IN HEADING 4818

Commencing the classification of nursing pads composed entirely of paper pulp, paper, cellulose wadding or webs of cellulose fibers, these nursing pads, in accordance with the dictates of GRI 1, are classified according to the terms of heading 4818, HTSUS. Heading 4818, HTSUS, provides for the classification of:

Toilet paper and similar paper…of a kind used for household or sanitary purposes;…diapers, tampons, bed sheets and similar household, sanitary or hospital articles, articles of apparel and clothing accessories, of paper pulp, paper, cellulose wadding or webs of cellulose fibers. (Emphasis added).

Explanatory Note 48.18 provides that heading 4818, HTSUS, addresses the classification of “household, sanitary or other hospital articles…of paper pulp, paper, cellulose wadding or webs of cellulose fibres.” Explanatory Note 44.18. Sanitary articles, in accordance with the definition of “sanitary” in Webster’s New Collegiate Dictionary are articles “of or relating to health.” Webster’s New Collegiate Dictionary, G. & C. Merriam Company (1977). It is the judgment of this office that nursing pads, designed to absorb excess milk from nursing mothers, are sanitary articles for the purposes of the tariff schedule and are similar to diapers and tampons, the sanitary articles designated eo nomine in heading 4818, HTSUS.

It is, therefore, Customs determination that nursing pads composed entirely of paper pulp, paper, cellulose wadding or webs of cellulose fibers are properly classified, pursuant to GRI 1, in heading 4818, HTSUS.

NURSING PADS WITH COMPONENTS OF PAPER PULP, PAPER, CELLULOSE WADDING OR WEBS OF CELLULOSE FIBERS AND OF TEXTILE FABRICS

Nursing pads for which the absorbent capability is provided by paper pulp, paper, cellulose wadding or webs of cellulose fibers, but which are not composed entirely of the materials enumerated in heading 4818, may not be classified pursuant to GRI 1 in heading 4818, HTSUS. These nursing pads generally have an absorbent inner layer or layers composed of paper pulp, paper, cellulose wadding or webs of cellulose fibers, but the outer layer or layers, those layers not primarily designed and intended to provide the article with its absorbent property, may generally be composed of one or more textile fabrics. The outer layer or layers may be, among other fabrics, lace, nonwoven fabrics or woven fabrics.

Nursing pads with an outer component of a textile fabric or fabrics and with an inner absorbent component of paper pulp, paper, cellulose wadding or webs of cellulose fibers may not be classified pursuant to GRI 1. A review of the terms of the headings of the HTSUS and the relevant section and chapter notes does not establish a heading into which an article of this nature may be properly classified, pursuant to GRI 1.

Having determined that General Rule of Interpretation 1 does not resolve this classification matter, the Customs Service reviewed GRI 2. Since nursing pads composed of an outer component of textile fabrics and with an inner absorbent component of the materials enumerated in heading 4818, HTSUS, that is, paper pulp, paper, cellulose wadding or webs of cellulose fibers, are not incomplete, unfinished, unassembled or disassembled articles, GRI 2(a) does not offer assistance. General Rule of Interpretation 2(b) does provide classification guidance.

General Rule of Interpretation 2(b) provides, in part, that “[t]he classification of goods consisting of more than one material or substance shall be classified according to the principles of rule 3.” Since the nursing pad subject to this discussion is composed of both a textile fabric component and a component of materials enumerated in heading 4818, HTSUS, it is composed of more than one material and resort must be had to GRI 3.

The initial sentence of General Rule of Interpretation 3 provides that “[w]hen, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be…” according to GRI 3(a), (b) or (c). The nursing pads subject to this discussion are, prima facie, classifiable in two headings. They are classifiable as “made up articles” of heading 6307, HTSUS, because of the textile fabric component and also as an article of heading 4818, HTSUS, because of their similarity to the eo nomine articles and composition of paper pulp, paper, cellulose wadding or webs of cellulose fibers.

General Rule of Interpretation 3(a) states that “when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods…those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the goods.” The nursing pad subject to this discussion is a composite good and the headings under classification consideration each refer to only part of the materials in the good. Customs will, for that reason, turn to GRI 3(b).

General Rule of Interpretation 3(b) provides, in part, that “composite goods…made up of different components…which cannot be classified by reference to 3(a), shall be classified as if they consisted of the …component which gives them their essential character, insofar as this criterion is applicable.” The GRI’s do not provide a definition for the phrase “essential character,” but the EN’s suggest an illustrative list of factors to consider. Explanatory Note Rule 3(b) (VIII) states that the factors that may be relevant to the determination of “essential character” “will vary between different kinds of goods,” but may include the nature of the material or component, its bulk, its quantity, its weight, its value or the role played by the constituent material in relation to the use of the good. General Rules for the Interpretation of the Harmonized System, Rule 3 (b) Explanatory Note (VIII).

It is the conclusion of the Customs Service that the absorbent component composed of a material enumerated in heading 4818, HTSUS, is the component that gives the nursing pad its essential character. The absorbent material component plays the greatest role in the nursing pad, the absorption of excess milk during lactation. It is also the component that provides the nursing pad with its greatest bulk.

It is, therefore, Customs determination that nursing pads composed of an outer component of a textile fabric or fabrics and with an inner absorbent component of paper pulp, paper, cellulose wadding or webs of cellulose fibers are properly classified, pursuant to GRI 3(b), in heading 4818, HTSUS, as a similar sanitary article.

Nursing Pads of Textile Wadding – Heading 5601

COMPOSED ENTIRELY OF TEXTILE WADDING

Commencing the classification of nursing pads composed entirely of textile wadding, these nursing pads, pursuant to GRI 1, are properly classified in heading 5601, HTSUS. Heading 5601, HTSUS, provides for the classification of “Wadding of textile materials and articles thereof; textile fibers, not extending 5 mm in length (flock), textile dust and mill neps.”

Wadding, as described by the EN’s is “made by superimposing several layers of carded or air-laid textile fibres one on the other, and then compressing them in order to increase the cohesion of the fibres.” Explanatory Note 56.01(A). It is noted that in order for an article to be wadding, the fibers must be readily separable, such as is possible with cotton balls frequently found in medicine bottles. See Explanatory Note 56.01(A).

Heading 5601, HTSUS, provides for the classification of articles of “[w]adding of textile materials.” The Explanatory Notes reinforce the classification of nursing pads composed entirely of textile wadding in heading 5601, HTSUS. Explanatory Note 56.01(A)(2) sets forth that “[s]anitary towels and tampons, napkins (diapers) and napkin liners for babies and similar sanitary articles consisting of wadding, whether or not with knitted or loosely woven open-work covering” are classified in heading 5601, HTSUS. Customs, as previously addressed, has concluded that nursing pads are similar to sanitary articles.

It is, therefore, Customs determination that nursing pads composed entirely of textile wadding are properly classified, pursuant to GRI 1, in heading 5601, HTSUS, as articles of wadding of textile materials.

NURSING PADS WITH COMPONENTS OF TEXTILE WADDING AND OF TEXTILE FABRICS

Nursing pads for which the absorbent capability is provided by textile wadding, but which are not composed entirely of textile wadding, may not be classified pursuant to GRI 1 in heading 5601, HTSUS. These nursing pads generally have an absorbent inner component of textile wadding, but also have outer components, not primarily designed and intended to provide the article with its absorbent property, composed of one or more textile fabrics. The outer components may be, among other fabrics, lace, nonwoven fabrics that are not wadding or woven fabrics.

Nursing pads composed of an outer component of textile fabric and with an inner absorbent component of textile wadding may not be classified pursuant to GRI 1. A review of the terms of the headings of the HTSUS and the relevant section and chapter notes does not establish a heading into which an article of this nature is properly classifiable, pursuant to GRI 1.

Having determined that General Rule of Interpretation 1 does not resolve this classification matter, the Customs Service reviewed GRI 2. Since nursing pads composed of an outer component of textile fabrics and an inner absorbent component of textile wadding are not incomplete, unfinished, unassembled or disassembled articles, GRI 2(a) does not offer assistance. General Rule of Interpretation 2(b) does provide classification guidance.

General Rule of Interpretation 2(b) provides, in part, that “[t]he classification of goods consisting of more than one material or substance shall be classified according to the principles of rule 3.” Since the nursing pad subject to this discussion is composed of both textile fabrics and textile wadding, it is composed of more than one material and resort must be had to GRI 3.

The initial sentence of General Rule of Interpretation 3 provides that “[w]hen, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be…” according to GRI 3(a), (b) or (c). The nursing pads subject to this discussion are, prima facie, classifiable in two headings. They are classifiable as “made up articles” of heading 6307, HTSUS, because of the textile fabric component and also as an article of “[w]adding of textile materials” of heading 5601, HTSUS, because of the textile wadding component. See Headings 5601 and 6307, HTSUS.

General Rule of Interpretation 3(a) states that “when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods…those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the goods.” The nursing pad subject to this discussion is a composite good and the headings under classification consideration each refer to only part of the materials in the good. Customs will, for that reason, turn to GRI 3(b).

General Rule of Interpretation 3(b) provides, in part, that “composite goods…made up of different components…which cannot be classified by reference to 3(a), shall be classified as if they consisted of the …component which gives them their essential character, insofar as this criterion is applicable.” The GRI’s do not provide a definition for the phrase “essential character,” but the EN’s suggest an illustrative list of factors to consider. Explanatory Note Rule 3(b) (VIII) states that the factors which may be relevant to the determination of “essential character” “will vary between different kinds of goods,” but may include the nature of the material or component, its bulk, its quantity, its weight, its value or the role played by the constituent material in relation to the use of the good. General Rules for the Interpretation of the Harmonized System, Rule 3 (b) Explanatory Note (VIII).

It is the conclusion of the Customs Service that the inner absorbent component composed of textile wadding is the component that gives the nursing pad its essential character. The absorbent component plays the greatest role in the nursing pad, the absorption of excess milk during lactation. It is also the component that provides the nursing pad with its greatest bulk.

It is, therefore, Customs determination that nursing pads composed of an outer component of textile fabrics and with an inner absorbent component of textile wadding are properly classified, pursuant to GRI 3(b), in heading 5601, HTSUS, as articles of wadding of textile materials.

Nursing Pads of Woven Fabric or of Nonwoven Fabric, But Not Wadding – Heading 6307

Heading 6307, HTSUSA, a residual heading, provides for the classification of “Other made up articles, including dress patterns.” It is Customs determination, pursuant to GRI 1, that heading 6307, HTSUSA, and no other heading, provides for the classification of nursing pads composed entirely of woven textile fabrics or of nonwoven textile fabrics that are not wadding.

The expression “made up,” as used in heading 6307, HTSUSA, is defined in Section XI, note 7. “Made up,” pursuant to the section note, means articles,

Cut otherwise than into squares or rectangles; Produced in the finished state, ready for use (or merely needing separation by cutting dividing threads) without sewing or other working (for example, certain dusters, towels, tablecloths, scarf squares, blankets); Hemmed or with rolled edges, or with a knotted fringe at any of the edges, but excluding fabrics the cut edges of which have been prevented from unravelling by whipping or by other simple means; Cut to size and having undergone a process of drawn thread work; Assembled by sewing, gumming or otherwise (other than piece goods consisting of two or more lengths of identical material joined end to end and piece goods composed of two or more textiles assembled in layers, whether or not padded); or Knitted or crocheted to shape, whether presented as separate items or in the form of a number of items in the length.

The Explanatory Notes to heading 6307, HTSUSA, indicate that this heading is intended to include made up articles of any textile material, provided the articles are “not included more specifically in other headings of Section XI or elsewhere in the Nomenclature.” Explanatory Note 63.07. Explanatory Note 63.07 further provides that made up articles include “[s]anitary towels (excluding those of heading 56.01).” Explanatory Note 63.07 (14). The EN’s do not define “sanitary towels,” but a review of the Explanatory Notes to heading 5601, HTSUS, suggests that sanitary towels are similar to “[s]anitary…tampons, napkins (diapers) and napkin liners for babies and similar sanitary articles….” Explanatory Note 56.01(A)(3). These sanitary articles are similar to those addressed in the analysis of heading 4818, HTSUS. The reasoning set forth concerning sanitary articles of heading 4818, HTSUS, is equally applicable to sanitary towels and articles of heading 6307, HTSUS.

It is, therefore, Customs determination that nursing pads composed entirely of woven textile fabrics or of nonwoven textile fabrics that are not wadding are not included more specifically elsewhere in the schedule, that they are described by section XI, note 7 and are properly classified at the heading level in heading 6307, HTSUS. Sanitary towels referenced in the Explanatory Notes, which Customs notes is not a term routinely employed in the United States, are a type of sanitary article. Nursing pads, as addressed previously, are sanitary articles.

Clothing Accessories and Heading 6217

The Customs Service has previously issued ruling letters classifying nursing pads, without regard to the material or substance that afforded the article its absorbent capability, in heading 6217, HTSUS. Heading 6217, HTSUS, provides, in part, for the classification of “Other made up clothing accessories….” (Emphasis added). Customs has now determined, subsequent to an exhaustive review of the tariff schedule and the Explanatory Notes, that nursing pads are not clothing accessories and should not be classified in heading 6217, HTSUS.

Customs conclusion that nursing pads were clothing accessories was based on a review of the Explanatory Notes and the decision that nursing pads are “accessories,” that is, that they are secondary or subordinate in importance to clothing articles, adding to the beauty, convenience and effectiveness of the article. It is now Customs determination that nursing pads are not “accessories” and that Explanatory Note 62.17, when read in its entirety, does not support the classification of nursing pads in heading 6217, HTSUS.

Explanatory Note 62.17 lists twelve categories of articles that should be classified as clothing accessories, or as parts of garments or clothing accessories. The items enumerated in EN 62.17 include: dress shields; shoulder or other pads; belts of all kinds (including bandoliers) and sashes; muffs; sleeve protectors; sailor’s collars; epaulettes and brassards; labels, badges, emblems, “flashes” and the like; frogs and lanyards; separately presented removable linings for raincoats and similar garments; pockets, sleeves, collars, collarlettes, wimples, fallals of various kinds, cuffs, yokes, lapels and similar items; and stockings, socks and sockettes.

Customs had previously placed considerable emphasis on the similarities between dress shields and shoulder pads, and nursing pads. It is now the determination of this office that Customs should not focus on only dress shields and shoulder pads when attempting to draw analogies to nursing pads, but must take into consideration all of the items listed in the Explanatory Note.

Nursing pads, like dress shields, are worn in addition to the wearer’s clothing and do protect the wearer’s clothing from perspiration staining. Dress shields, unlike nursing pads, are principally intended to protect the wearer’s clothing. While nursing pads will protect the wearer’s brassiere and outer garment from possible staining, its primary use is to absorb excess milk, not protect the wearer’s clothing, particularly the brassiere. Nursing mothers wear nursing brassieres for a limited period of time and concerns about staining are minimal. Customs notes that nursing pads are generally purchased from maternity stores or drug stores, where as dress shields are generally purchased in fabric stores.

Shoulder pads are designed and intended to complement the wearer’s clothing and, unlike nursing pads, have no protective function. Customs, as previously discussed, has concluded that the use of nursing pads for any purpose other than the absorption of excess milk during lactation is fugitive. Should pads, in this regard, are not analogous to nursing pads.

A review of all of the items listed in EN 62.17 convinces Customs that nursing pads are not properly classified in heading 62.17, HTSUS. While nursing pads do have similarities with dress shields and shoulder pads, particularly dress shields, Customs concludes that a fair and accurate interpretation of EN 62.17 necessitates that nursing pads be compared to all of the items listed. When the features and uses of nursing pads are weighted against the features and uses of all of the items enumerated in EN 62.17, it is evident to Customs that nursing pads are not sufficiently analogous and should not be classified in heading 6217, HTSUS. Nursing pads have little or nothing in common with items such as belts, sashes muffs, sleeve protectors, sailor’s collars, epaulettes, brassards, labels, badges, emblems, “flashes,” frogs, lanyards, removable linings for raincoats, pockets, sleeves, collars, collarlettes, wimples, fallals, cuffs, yokes, lapels, stockings, socks and sockettes.

The Customs Service is aware of HQ 963488 (May 2, 2000) and NY D82853 (Oct. 16, 1998) classify similar nursing pads as clothing accessories in heading 6217, HTSUS. Customs is re-examining the classification of this merchandise in heading 6217, HTSUS. If a decision is made to reclassify the merchandise in the identified ruling letters, the Customs Service will proceed in accordance with 19 U.S.C. 1625 (c).

TL Care’s Nursing Pad of Woven Cotton Fabric

Commencing classification of the TL Care nursing pad, in accordance with the dictates of GRI 1, the Customs Service examined the headings of the HTSUSA. Heading 6307, HTSUSA, a residual heading, provides for the classification of “Other made up articles, including dress patterns.” It is Customs determination, as previously set forth in this ruling letter, that heading 6307, HTSUSA, and no other heading, provides for the classification of nursing pads composed entirely of woven cotton fabric.

It is Customs determination that nursing pads composed entirely of woven cotton fabric are not included more specifically elsewhere in the schedule and that they are articles assembled by sewing, gumming or otherwise as describe by section XI, note 7 (e). Nursing pads, as previously resolved, are sanitary articles similar to sanitary towels.

Continuing the classification of TL Care’s nursing pad composed solely of four layers of 100 percent woven cotton fabric, the article is classified in subheading 6307.90.9889, HTSUSA. Subheading 6307.90.9889, HTSUSA, provides for the classification of:

Other made up articles, including dress patterns:

Other:

Other: Other, Other: 6307.90.9889 Other.

HOLDING

The TL Care nursing pad, composed entirely of woven cotton fabric, is classified in subheading 6730.90.9889, Harmonized Tariff Schedule of the United States Annotated.

The General Column 1 Rate of Duty is seven (7) percent, ad valorem.

Sincerely,

Myles B. Harmon, Acting Director
Commercial Rulings Division