CLA-2-39:S:N:N6:221 807514

Mr. Steve Beber
J. Fanok Services, Inc.
5200 West Side Avenue
North Bergen, NJ 07047

RE: The tariff classification of radiator insulator panel from the United Kingdom.

Dear Mr. Beber:

In your letter dated February 28, 1995, on behalf of Novitherm USA, Inc, you requested a tariff classification ruling.

The radiator insulation panel is composed of metallized polyvinyl chloride plastic. The panel is used as a reflector for radiators and baseboard heaters. Through the application of an adhesive, the panel is secured to the wall behind the radiator or heater. The panel thermodynamically sweeps warm air from behind the radiator back into the room, evenly heating the room and conserving energy.

You have suggested classification in subheading 3921.90.50, HTS, which provides for certain plastic sheet. The panel, however, with its various rows of ridges, is advanced beyond the definition of sheet provided in legal note 10 of chapter 39 of the Harmonized Tariff Schedule.

The applicable subheading for the radiator insulator panel will be 3925.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for builders' ware of plastics, not elsewhere specified or included: other. The rate of duty will be 5.3 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