CLA-2-70:OT:RR:NC:N1:126
Danielle Henthorn
Armacell LLC
55 Vilcom Center Dr #200
Chapel Hill, North Carolina 27514
RE: The tariff classification of two fiberglass insulating products from Korea
Dear Ms. Henthorn:
In your letter dated May 12, 2022, you requested a tariff classification ruling.
Two representative samples were submitted and sent to our Customs and Border Protection (CBP) laboratory for analysis. This analysis has been completed.
The subject articles, designated as ArmaGel HT and ArmaGel DT, are described as insulation blankets used in high temperature applications and for cryogenic and dual-temperature applications. You state in your letter that ArmaGel HT is suitable for elevated temperature applications with maximum operating temperatures up to 1200 degrees Fahrenheit. Both products are used in applications for thermal insulation/protection of pipes, vessels, and ducts (including elbows, fittings, flanges, etc.) in industrial (typically oil and gas) and process equipment facilities. You further state the insulation blankets are comprised of fiberglass filament yarns between 7 - 10 microns in diameter and weigh approximately 1000 – 2000 grams per square meter. Both products are also used to provide acoustic insulation on industrial pipework and vessels to reduce sound transmission.
Our CBP laboratory has determined that the ArmaGel HT and ArmaGel DT consist of non-woven fiberglass felt. Both products are dark grey in color. The ArmaGel DT has an aluminum coating on the top layer. You state in your letter that the insulation blankets provide thermal protection.
ArmaGel HT and ArmaGel DT are composite goods comprised of different materials that are classifiable in different headings, 7019 (fiberglass) and heading 7607 (aluminum). Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs) taken in order. General Rule of Interpretation (GRI) 3(b) of the Harmonized Tariff Schedule of the United States (HTSUS) provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The fiberglass component provides the essential character of this item.
The essential character of the insulation blankets is imparted by the non-woven insulating fiberglass component. The non-woven fiberglass component within each article provides the thermal insulation protection for the pipes, vessels, and ducts (including elbows, fittings, flanges, etc.).
The applicable subheading for ArmaGel HT and ArmaGel DT will be 7019.69.9021, HTSUS, which provides for glass fibers (including glass wool) and articles thereof (for example, yarn, rovings, woven fabrics): Mechanically bonded fabrics: Other: Colored: Other...Weighing more than 215 grams per square meter, with a filament diameter of 7 to 13 microns”. The general rate of duty will be 7 percent ad valorem.
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 the 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 Elena Pietron at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division