The tariff classification of three polymerized rosin compounds from China.

N010247 May 21, 2007 CLA-2-38:RR:E:NC:N2:235 CATEGORY: Classification TARIFF NO.: 3806.30.0000; 3806.90.0000 Mr. Max L. Turnipseed MCT International P. O. Box 66302 Baton Rouge, Louisiana 70896-6302 RE: The tariff classification of three polymerized rosin compounds from China. Dear Mr. Turnipseed: In your letter dated April 24, 2007 you requested a tariff classification ruling on behalf of your client Eastman Chemical Company. The subject merchandise consists of three different polymerized rosin compounds as follows: Dymerex polymerized rosin, Poly-pale partially dimerized rosin and Poly-pale Ester 10. You indicate that both the Dymerex and Poly-pale rosin products are dimerized gum rosins, catalyzed with sulfuric acid. Based on the literature provided, Dymerex and Poly-pale differ from each chemically, only with regards to the percentages of the constituent chemical components, as indicated below. The Dymerex polymerized rosin (CAS # 65997-05-9), as described in the literature you submitted, is a pale, acidic, thermoplastic, high softening point resin. It is composed primarily of dimeric acids, derived from rosin, with lesser amounts of monomeric resin acids and neutral materials of rosin origin. Dymerex contains fifty to sixty-five percent dimer acid, and twenty to thirty-five percent mono abietic acid. The compound is used in a variety of products and applications, as noted in your product data sheet. It is imported packed in aluminum kraft bags of 25 kilograms net weight each on shrink wrapped pallets of 28 bags each. Poly-pale (CAS # 65997-05-9), as described in the literature you submitted, is a partially dimerized rosin. It has a higher softening point, higher viscosity, and much greater resistance to oxidation. It does not readily crystallize in solid form, or solution. Poly-pale contains twenty to forty percent dimer acid, and forty to seventy-five percent mono abietic acid. The literature provided with your request indicates that its chemical characteristics allow it to be used in a variety of products including varnishes, driers, synthetic resins, and protective coatings. It is imported packed in aluminum kraft bags of 25 kilograms net weight each on shrink wrapped pallets of 28 bags each. Poly-pale Ester 10 is a glycerol ester of dimerized gum rosin. It is a hard, pale amber colored thermoplastic resin, and is described as the glycerol ester of dimerized (polymerized) rosin, catalyzed with sulfuric acid. It is composed of glycerol derived mono, di, and tri-esters of dimerized gum rosin. Poly-pale Ester 10 is indicated for use in lacquers varnishes, adhesives, certain cosmetics, and various other products. Poly-pale Ester 10 is packed in aluminum kraft bags of 25 kilograms net weight and imported on shrink wrapped pallets of 30 bags each. In addition to the packing weights and quantities listed above, you indicate in your letter that the merchandise may be imported in 220 kilogram fiber drums, or 500 kilogram bags. The applicable subheading for the Dymerex Polymerized rosin and the Poly-pale partially dimerized rosin will be 3806.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for rosin and resin acids, and derivatives thereof; rosin spirit and rosin oils; run gums: other. The rate of duty will be 4.2 percent ad valorem. The applicable subheading for the Poly-pale Ester 10 will be 3806.30.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for for rosin and resin acids, and derivatives thereof; rosin spirit and rosin oils; run gums: ester gums. The rate of duty will be 6.5 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 World Wide Web at http://www.usitc.gov/tata/hts/. 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 Paul Hodgkiss at 646-733-3046. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division