NY 850769
Apr 11 1990

CLA-2-32:S:N:N01:236 850769

Mr. Mervyn R. Litzow
Wyatt Marketing Corp.
P.O. Box 274
249 S. Franklin Street
Chagrin Falls, Ohio 44022

RE: The tariff classification of "Resutile", "Resutop", & "Resuseal" (Coatings) from England

Dear Mr. Litzow:

In your letter dated March 13, 1990 you requested a tariff classification ruling on the following three protective coatings:

1. "Resutile" is a 2-part polyurethane wall and floor coating for both interior and exterior application. It consists of a polyurethane polymer, solvents, and pigment. It is used as chemical and corrosion resistant coating applied by brush, roller, or spray with a film thickness per coat of approximately 75 microns (3 mills). The applicable subheading for the "Resutile" will be 3208.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a nonaqueous medium. The rate of duty will be 3.2 percent ad valorem.

2. "Resutop" is a two part solvent and water free epoxide resin system containing pigments. It is used as a corrosion and wear resistant coating applied by brushing, rollering and\or squeegee coating techniques leaving a film thickness of approximately 200 microns per coat (8 mills).

The applicable subheading for the "Resutop" will be 3210.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other paints and varnishes. The rate of duty will be 1.8 percent ad valorem.

3. "Resuseal" is a two part epoxide resin aqueous system which may be used with or without pigments. It is used both as a primer and final protective coating on concrete. Resuseal can be applied with a roller or brush.

The applicable subheading for the "Resuseal" will be 3209.90.0000. Harmonized Tariff Schedule of the United States (HTS), which provides for other paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in an aqueous medium. The rate of duty will be 5.9 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