CLA-2-35:OT:RR:NC:N3 135
Ahn Jaehong
Core-Packing
Ilbansaneop-gil, Namsang-myeon, Geochang-gun Kyungsang namdo South Korea
RE: The tariff classification of a glue from South Korea
Dear Ms. Jaehong:
In your letter dated April 25, 2023, you requested a tariff classification ruling.
The product in your letter is identified as “Prepared Adhesive,” a yellow-brown powder imported in flexible intermediate bulk containers in units of 500 kg. It consists of 55 percent calcium carbonate, 27 percent dextrin, 8 percent calcium hydroxide, 5 percent sodium carbonate, 3 percent borax, and 2 percent dispersant. After importation, it will be mixed with water to make adhesive and used in the production of paper tubes.
In your letter, you suggest that the product should be classified in heading 3506, Harmonized Tariff Schedule of the United States, HTSUS, which covers, in relevant part, “[p]repared glues and other prepared adhesives, not elsewhere specified or included.” We disagree. Although the calcium carbonate is a large percentage of the formulation, based on our research it is merely a filler used to reduce cost and improve certain properties of the glue. However, the dextrin is the primary ingredient possessing adhesive properties that forms the glue. The “Prepared Adhesive” is a dextrin-based formulation which is more specifically provided for in heading 3505, HTSUS.
The applicable subheading for the “Prepared Adhesive” will be 3505.20.0000, HTSUS, which provides for glues based on starches, or on dextrins or other modified starches: [g]lues. The rate of duty will be 2.1 cents per kilogram plus 2.9 percent ad valorem.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency (EPA). Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at 800-471-7127, by e-mailing to [email protected], or by visiting their website at www.epa.gov.
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 at https://hts.usitc.gov/current
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division