CLA-2-30:S:N:N7:238 894238

Mr. Jeremy Eakin
T.G. Eakin Ltd.
965 Upper Newtownards Road
Dundonald, Belfast BT16 ORL
Northern Ireland

RE: The tariff classification of Cohesive Seals from the United Kingdom

Dear Mr. Eakin:

In your letter dated January 20, 1994, you requested a tariff classification ruling.

The submitted samples consist of "donut"-shaped cohesive seals, which you describe as adhesive skin barriers, made up in two sizes: small (1 7/8" outer diameter) and large (3 7/8" outer diameter). The seals are composed of polybutene, sodium carboxymethylcellulose, and a carbohydrate mixture; have an adhesive layer on both sides; and are not coated or impregnated with pharmaceutical substances. They are mouldable, and can be stretched or compressed to the exact shape or size required without the need to be cut to fit. You indicate that the seals are mostly used by ostomy patients for skin protection around stomas, but can also be used around fistulas, tube drains, or any wound which requires special dressing and draining. The seals are put up in shrink-wrapped packages for retail sale. As the seals are neither coated nor impregnated with pharmaceutical substances, the applicable subheading for the subject merchandise will be 3005.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for adhesive dressings and other articles having an adhesive layer: other. The rate of duty will be 7 percent ad valorem.

This merchandise may be subject to the regulations of the Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, MD 20857, telephone number (301) 443-6553.

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