CLA-2-70:RR:NC:2:226 H88452
Mr. Mike Buhl
Weldas Company
128 Seaboard Lane
Franklin, Tennessee 37067
RE: The tariff classification of welding blankets from China
Dear Mr. Buhl:
In your letter dated February 27, 2002, you requested a tariff classification ruling. Representative samples were submitted with your ruling request.
The merchandise at issue is described as “Welding Blankets”. You indicated in your letter that these products are designed to be used as tarps to cover and protect items from welding sparks and splatter. Each welding blanket contains an acrylic and neoprene coating.
The blankets include items consisting of 100 percent fiberglass fabric, items consisting of 60 percent aramid and 40 percent fiberglass fabric, and items consisting of 95 percent silica and 5 percent oxides.
You stated in your letter that you wish to export rolls of uncut fabric to China. In China, the fabric will be cut, sewn, packaged and sent back to the United States as a finished product. The finished product will have hems and grommets. Each product is identified with a part number. The part number and dimensions of the articles composed of 100 percent fiberglass fabric, which will be used to make welding blankets, are as follows:
50-1466, 14 oz. Salmon (6’X6’)
50-2366, 23 oz. Black Glass (6’ X 6’)
50-2368, 23 oz. Black Glass (6’ X 8’)
50-3066, 30 oz. Gold Glass (6’ X 6’)
50-3068, 30 oz. Gold Glass (6’ X 8”)
The applicable subheading for the welding blankets composed of 100 percent fiberglass will be 7019.90.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for glass fibers (including glass wool) and articles thereof (for example, yarn, woven fabrics)…: other: other: other. The rate of duty will be 4.3 percent ad valorem.
The part number and dimensions of the articles composed of 60 percent aramid and 40 percent fiberglass fabric, which will be used to make welding blankets, are as follows:
50-2466, 23 oz. Black Aramid Glass (6” X 6”)
50-2468, 23 oz. Black Aramid Glass (6’ X 8”)
The applicable subheading for the welding blankets composed of 60 percent aramid and 40 percent fiberglass will be 6306.12.0000, HTS, which provides for tarpaulins, awnings and sunblinds, of synthetic fibers. The rate of duty will be 9 percent ad valorem.
HTS 6306.12.0000 falls within textile category designation 669. However, there are currently no quota or visa requirements applicable to products of China in this category.
With regard to fabric composed of 95 percent silica and 5 percent oxides used in products with part numbers 50-1833, 50-1866, 50-3633 and 50-3666 that you wish to import, additional information is needed before we can issue a tariff classification ruling.
Please submit a complete chemical flow chart indicating every step in the production and derivation of the silica and oxides within these products. Is the silica a material derived from the ground or is it a synthetically produced material? Please explain fully.
How are the silica and oxides combined? Do they react together to change the molecule of these materials? Even if the production process begins with natural silica, does the molecule of this substance change during the process? Please explain fully.
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 646-733-3027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division