CLA-2-68:RR:NC:2:226 B84834

Ms. Brenda Phillips
Cargo U.K., Inc.
3809 Beam Road, Suite D
Charlotte, NC 28217

RE: The tariff classification of abrasive fining pads and polishing/buffing pads from England

Dear Ms. Phillips:

In your letter dated April 24, 1997, on behalf of your client, Salem Distribution, you requested a tariff classification ruling regarding abrasive fining pads and polishing/buffing pads. Representative samples were submitted with your ruling request.

You indicated in your letter that the fining pad is composed of a silicon carbide abrasive which is adhered to a paper base by a very thin layer of phenolic resin. The opposite side of the paper contains a pressure sensitive acrylic adhesive which is necessary to facilitate its placement on the fining machine. The pad (disposable) will be used to fine plastic ophthalmic lenses prior to polishing.

The second item is identical in configuration to the first item (abrasive fining pad). The only significant difference is the fact that the rubbing or buffing surface is composed of a textile flock on top of a woven fabric. The back surface also contains a pressure sensitive adhesive necessary to facilitate its placement on the polishing device. There is no abrasive material present on the polishing pad. The pad (disposable) will be used to polish ophthalmic lenses.

The applicable subheading for the abrasive fining pads will be 6805.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for natural or artificial abrasive powder or grain, on a base of textile material, of paper, of paperboard or of other materials, whether or not cut to shape or sewn or otherwise made up: on a base of paper or paperboard only. The rate of duty will be 1 percent ad valorem.

The applicable subheading for the polishing pads will be 5911.90.0080, HTS, which provides for textile products and articles, for technical uses. The rate of duty will be 6.4 percent ad valorem.

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 Jacob Bunin at 212-466-5796.

Sincerely,

Gwenn Klein Kirschner
Chief, Special Products Branch
National Commodity
Specialist Division