CLA-2-39:S:N:N7:238 802684

John M. Peterson, Esq.
80 Broad Street
Suite 3400
New York, NY 10004

RE: The tariff classification of Polyisobutylene (CAS Reg No. 9003-29-6), in clay form, from Japan

Dear Mr. Peterson:

In your letter dated September 19, 1994, on behalf of your client, Detail Plus Auto Detailing Systems, Inc., you requested a tariff classification ruling.

The submitted sample, a gray-colored solid, is composed of non-elastomeric polyisobutylene (99%) and a plasticizer (1%). Because of its moldable characteristics, the product can be formed into various shapes and sizes. You indicate that, in its imported condition, the polyisobutylene clay will be in the form of a moldable gray-colored brick, which may be divided into smaller pieces, for use in removing detergents, dirt, wax and grime from painted surfaces of automobiles.

The applicable subheading for the subject product will be 3902.20.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for: "Polymers of propylene or of other olefins, in primary forms: Polyisobutylene: Other." The rate of duty will be 1.8 cents per kilogram plus 7.5 percent ad valorem.

This merchandise may be subject to the regulations of the Environmental Protection Agency, Office of Pesticides and Toxic Substances. You may contact them at 402 M Street, S.W., Washington, D.C. 20460, telephone number (202) 554-1404, or EPA Region II, at (908) 321-6669.

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