CLA-2-37:RR:NC:SP:236 K87956

Mr. Alan Price
Wiley Rein and Fielding
1776 K Street NW
Washington, DC 20006

RE: The tariff classification of APR 600 thermal transfer ribbon from France

Dear Mr. Price:

In your letter dated July 8, 2004 you requested a tariff classification ruling on behalf of your client Armor U.S.A.

The descriptive literature included with your request states that the APR 600 is a jumbo roll of a specific color thermal transfer ribbon (TTR). In your letter you state that the standard TTR roll is 740 mm wide and 7,500 meters long and that the jumbo rolls of TTR are neither in a cartridge nor a plastic housing with gears. Your literature states that the APR 600 TTR is specifically designed to be used in color thermal transfer printers that print graphics with automatic data processing equipment.

The applicable subheading for the APR 600 thermal transfer ribbon will be 3702.41.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles; instant print film in rolls, sensitized, unexposed: Other film, without perforations, of a width exceeding 105mm: Of a width exceeding 610 mm and of a length exceeding 200m, for color photography. The rate of duty will be 3.7 percent ad valorem.

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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division