CLA-2-48:RR:NC:SP:234 L84403

Mr. David Cohen
Sandler, Travis & Rosenberg, P.A.
1300 Pennsylvania Avenue, N.W.
Washington, D.C. 20004-3002

RE: The tariff classification of various grades of release paper.

Dear Mr. Cohen:

In your letters dated February 11 and April 15, 2005, you requested a tariff classification ruling on behalf of S. D. Warren Company d/b/a Sappi Fine Paper North America.

Technical data and samples representing six grades of paper, all belonging to a group known as “Classic” release paper, were submitted for our examination. The submitted samples have since been analyzed by our laboratory, whose findings are summarized in the descriptions that follow. It is noted that all of the papers will be supplied in the form of rolls exceeding 15 cm in width.

The sample identified as “Rubberleaf CZ” is found to be a cream-colored paper coated on both sides with an inorganic material. It is composed of chemical bleached kraft pulp fibers, weighs 168.83 grams per square meter, and has a total thickness of 0.19 mm.

The sample identified as “Versakote” is found to be a cream-colored paper coated on one side with an inorganic substance. It is composed of chemical bleached kraft pulp fibers, weighs 151.59 grams per square meter, and has a total thickness of 0.189 mm.

The applicable subheading for the “Rubberleaf CZ” and “Versakote” papers will be 4810.32.1060, Harmonized Tariff Schedule of the United States (HTS), which provides for Paper and paperboard, coated on one or both sides with kaolin or other inorganic substances … : Kraft paper and paperboard, other than that of a kind used for writing, printing or other graphic purposes: Bleached uniformly throughout the mass and of which more than 95 percent by weight of the total fiber content consists of wood fibers obtained by a chemical process and weighing more than 150 g/m2: In strips or rolls of a width exceeding 15 cm … : Other (than certain enumerated kinds).

The sample identified as “Transkote EHR” is found to be a paper coated on one side with a plastic material. It is composed of chemical bleached kraft pulp fibers, weighs 157.74 grams per square meter and has a total thickness of 0.163 mm.

The sample identified as “Transkote GEHR” is found to be a paper coated on one side with a plastic material. It is composed of chemical bleached kraft pulp fibers, weighs 155.28 grams per square meter and has a total thickness of 0.15 mm.

The sample identified as “Stripkote BOR SM” is found to be a paper coated on one side with a plastic material. It is composed of chemical bleached kraft pulp fibers with some unbleached pulp fibers, weighs 152.42 grams per square meter and has a total thickness of 0.179 mm.

The sample identified as “PER” is found to be a paper coated on one side with a plastic material. It is composed of chemical bleached kraft pulp fibers with some unbleached pulp fibers, weighs 174.33 grams per square meter and has a total thickness of 0.191 mm.

The applicable subheading for the “Transkote EHR,” “Transkote GEHR,” “Stripkote BOR SM,” and “PER” papers will be 4811.51.4000, HTS, which provides for paper and paperboard, coated, impregnated or covered with plastics: Bleached, weighing more than 150 g/m2: In strips or rolls of a width exceeding 15 cm … : Other (than certain enumerated kinds).

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

If you have any questions regarding the ruling, contact National Import Specialist Carl Abramowitz at 646-733-3037.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division