CLA-2 CO:R:C:G 087409 RFC

Mr. Gregory Kozak
Bradley International, Inc.
P.O. Box 307
Flint, MI 48501

RE: Revocation of Headquarters Ruling Letter 086449 and New York Ruling Letter 831157

Dear Mr. Kozak:

In Headquarters Ruling Letter (HRL) 086449, dated May 8, 1990, we advised you that New York Ruling Letter (NYRL) 831157, dated August 10, 1988 and issued in response to your request for a binding tariff classification ruling concerning a blended syrup, was revoked and that blended syrups are properly classified under subheading 2106.90.50, HTSUSA and, consequently, subject to the quota restrictions of subheading 9904.60.60, HTSUSA. The blended syrup which was the subject of a classification ruling in NYRL 831157 is a vanilla-flavored liquid sweetener said to contain not less than 65 percent sucrose, not more than 35 percent glucose, and vanillin or vanilla extract flavoring in the amount of one 55 gallon drum per 4,000 gallons of product.

Upon review and reconsideration, we have determined that the above-discussed blended syrup was misclassified in both HRL 086449 and NYRL 831157. As held in HRL 083695, blended syrups are properly classified under subheading 2106.90.5030, HTSUSA, which provides for food preparations not elsewhere specified or included, other, subject to quota established pursuant to Section 22 of the Agricultural Adjustment Act, as amended, provided for under heading 9904.50.20, HTSUSA. Subheading 9904.50.20, HTSUSA, provides for, in turn, blended syrups provided for under subheading 2106.90.50, HTSUSA, among other subheadings, containing sugars derived from sugar cane or sugar beets, capable of being further processed or mixed with similar or other ingredients and not prepared for marketing to the retail consumers in the identical form and package in which imported. Blended syrups, then, classified under subheading 2106.90.5030, HTSUSA, are subject to the quota restrictions of 9904.50.20,

HTSUSA, under which subheading there exists a total ban or embargo on the importation of these goods into the United States (i.e., none can be imported into the United States).

In light of the above, the above-mentioned blended-syrup product is properly classified under subheading 2106.90.5030, HTSUSA, and subject to the quota restrictions of subheading 9904.50.20, HTSUSA.

Both HRL 086449 and NYRL 831157 are hereby revoked pursuant to 19 CFR 177.9(d). Moreover, this revocation letter is applicable to all other rulings which may have been issued to you which are inconsistent with our position as stated in HRL 083695.

Sincerely,

John Durant, Director
Commercial Rulings Division