The tariff classification of impregnated felt polishing pads, from Japan.

NY E86436 September 23, 1999 CLA-2-59:RR:NC:TA:350 E86436 CATEGORY: Classification TARIFF NO.: 5911.90.0080 Mr. John F. McManus Itochu International Inc. 335 Madison Avenue New York, NY 10017 RE: The tariff classification of impregnated felt polishing pads, from Japan. Dear Mr. McManus: In your letter dated August 23, 1999, you requested a classification ruling. The supplier is Kanebo Ltd., Japan. You write that these pads are of a nonwoven fabric made from polyester staple fibers impregnated with polyurethane resin and the fabric is formed using the needlepunch method. This contradiction is discussed below. The material comes in various weights, all of which exceed 150 grams per square meter. A sample card, with six small different swatches was furnished. They were individually labeled with designations such as K0017, N0054 and N7512, but were not further identified as to their relative differences, other than being as samples of various grades of the goods in question. Although you refer to the fabric as a nonwoven, the manufacturer’s furnished production schematic (and also refers to “nonwoven fabric manufacturing process”) shows carding, cross lapping, and needle punching stations wherein this web is formed and taken up on a roll prior to the further manufacturing/finishing operations. We consider the base material to be of a needleloom construction and not that of a nonwoven. This needleloomed web is polyurethane impregnated, sanded, then finally finished by the addition, on the top surface, of a specialty polyurethane coating that, when cured, forms a soft nap layer that is further sanded to a smooth uniform surface. The finished fabric is cut into disks of between 30 and 60 inches in diameter, though other sizes may be ordered. The thickness of these pads will be from 1.1 mm to 1.45 mm. Finally, a Pressure Self-Adhesive backing (PSA) will be added. The thickness of the PSA is 0.24 mm, which includes the protective release paper. The trade name of these pads is “Bellatrix.” They will be used as polishing pads on flat surface polishing machines for polishing of silicon wafers used in the electronics industry. Other applications include polishing of magnetic aluminum disks, photomasks, and glass for liquid crystal display. These disks are considered to be an integral part of a polishing machine, therefore, the applicable subheading for the pads will be 5911.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for textile products and articles, for technical uses. The duty rate will be 5.6 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 George Barth at 212-637-7085. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division