CLA-2-56:S:N:N3H:350 868660

Mr. J. Damschroder
Feinstein & Norris, Inc.
3050 Mecom Rd., Bldg. 10
P.O. Box 60387
Houston, TX 77205

RE: The tariff classification of "Dryspill Rugs" for use in the absorption of oil, etc., from New Zealand. You state that the company you represent is International Enviroguard Systems, Inc.

Dear Mr. Damschroder:

In your letter which was undated and forwarded to us via U.S. Customs at Houston, TX, you requested a tariff classification ruling.

The instant merchandise, which you refer to as a "dryspill rug", is in actuality a wool pad which is designed for use in the absorption of oil spills, etc. It is composed of an open woven base scrim that has been obscured by the effect of the needling operation that was employed in the products manufacture. The pads measure about .125" in thickness and will be cut into various sizes for import into the United States. We assume, based upon the instant sample, that these pads will all be imported in a square or rectangular configuration.

The applicable subheading for the product will be 5602.10.9010, Harmonized Tariff Schedule of the United States (HTS), which provides for needleloom felt and stitch bonded fiber fabrics, of wool or fine animal hair. The rate of duty will be 12.5 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