CLA-2-48:OT:RR:NC:N1:130
Mr. James Wickstead
American River Group of Companies, LLC
10 Woodbridge Center Drive, Suite 420
Woodbridge, NJ 07095
RE: The tariff classification of cap liner roll stock from Canada
Dear Mr. Wickstead:
In your letter, dated September 19, 2018, you requested a tariff classification ruling on behalf of your client, Winpak Heat Seal Packaging, Inc. The request was returned for additional information, which was received by this office on November 29, 2018. Samples and product information were submitted for our review.
The item under consideration is identified as item LT3080, a semi-converted cap liner roll stock. The roll stock is a laminated product consisting of paper, aluminum foil, and plastic. The stock is utilized as a liner for bottle and container caps and protects the product contained inside. The stock, which exceeds 150 g/m2 in weight, is constructed of bleached, sulfate kraft paper laminated to aluminum foil with an adhesive. The foil is then laminated with adhesive to a sheet of polyethylene terephthalate (PET) film. The paper forms the stock base, the foil functions as an oxygen barrier, and the PET film functions as a resistance barrier to the container contents. The paper far exceeds two times the thickness of the aluminum foil, and the complete roll stock product measures less than 0.3mm in thickness. The stock is imported in rolls measuring approximately 40” in width.
In your letter, you suggest that the packaging materials are classifiable under subheading 4811.59.6000, HTSUS, as Paper, paperboard, cellulose wadding and webs of cellulose fibers, coated, impregnated, covered, surface-colored, surface-decorated or printed, in rolls or rectangular (including square) sheets, of any size, other than goods of the kind described in heading 4803, 4809 or 4810: Paper and paperboard, coated, impregnated or covered with plastics (excluding adhesives): Other: Other. However, we find that the specific dimensions of the product are more specifically described in a different subheading.
The bulk and weight of the paper far exceeds that of the foil and PET film components of the roll stock. The paper is bleached, and the product exceeds 150 g/m2. It is imported in rolls exceeding 15cm in width, and the product measures let than 0.3mm in thickness.
The applicable subheading for the LT3080 semi-converted cap liner roll stock will be 4811.51.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Paper, paperboard, cellulose wadding and webs of cellulose fibers, coated, impregnated, covered, surface-colored, surface-decorated or printed, in rolls or rectangular (including square) sheets, of any size, other than goods of the kind described in heading 4803, 4809 or 4810: Paper and paperboard, coated, impregnated or covered with plastics (excluding adhesives): Bleached, weighing more than 150 g/m²: In strips or rolls of a width exceeding 15 cm or in rectangular (including square) sheets with one side exceeding 36 cm and the other side exceeding 15cm in the unfolded state: Other (than 0.3mm or more in thickness). The rate of duty will be free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division