The tariff classification of a nonwoven laminated roofing underlayment from India
Issued July 26, 2024 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 5603.14.3000
Headings: 5603
Product description
In your letter and subsequent correspondence, you requested a classification ruling on your fabric designated as GAF Tiger Paw. The fabric is described as a laminated roofing underlayment designed to protect residential and light construction roofing systems by preventing water intrusion. The fabric is composed of: A top layer of spunbond non-woven fabric of filament polypropylene fibers weighing approximately 90 g/m2. It is light grey in color with a diamond embossed pattern. A first lamination layer primarily of low-density polyethylene (“LDPE”) weighing approximately 18 g/m2, with a layer of aluminum foil weighing approximately 20 g/m2. A second lamination layer, like the first primarily of LDPE, weighing approximately 18 g/m2. The bottom layer, like the top layer, is a spunbond non-woven fabric of filament polypropylene fibers weighing approximately 40 g/m2. It also is light grey in color with a diamond embossed pattern. A backside anti-skid layer made of primarily polypropylene, and LDPE weighing approximately 21 g/m2. The total fabric weight is approximately 207 g/m2, and it will be manufactured in India.
CBP rationale
The applicable subheading for the roofing underlayment will be 5603.14.3000, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “Nonwovens, whether or not impregnated, coated, covered or laminated: Of man-made filaments: Weighing more than 150 g/m2: Laminated fabrics.
Full text
N340992 July 26, 2024 CLA-2-56:OT:RR:NC:N2:350 CATEGORY: Classification TARIFF NO.: 5603.14.3000 Maria Garza Intertape Polymer Group 50 Abbey Ave.Truro, Nova Scotia B2N6W4Canada RE: The tariff classification of a nonwoven laminated roofing underlayment from India Dear Ms. Garza: In your letter dated June 28, 2024, you requested a tariff classification ruling. A sample was submitted and will be retained for training purposes. In your letter and subsequent correspondence, you requested a classification ruling on your fabric designated as GAF Tiger Paw. The fabric is described as a laminated roofing underlayment designed to protect residential and light construction roofing systems by preventing water intrusion. The fabric is composed of: A top layer of spunbond non-woven fabric of filament polypropylene fibers weighing approximately 90 g/m2. It is light grey in color with a diamond embossed pattern. A first lamination layer primarily of low-density polyethylene (“LDPE”) weighing approximately 18 g/m2, with a layer of aluminum foil weighing approximately 20 g/m2. A second lamination layer, like the first primarily of LDPE, weighing approximately 18 g/m2. The bottom layer, like the top layer, is a spunbond non-woven fabric of filament polypropylene fibers weighing approximately 40 g/m2. It also is light grey in color with a diamond embossed pattern. A backside anti-skid layer made of primarily polypropylene, and LDPE weighing approximately 21 g/m2. The total fabric weight is approximately 207 g/m2, and it will be manufactured in India. The applicable subheading for the roofing underlayment will be 5603.14.3000, Harmonized Tariff Schedule of the United States (“HTSUS”), which provides for “Nonwovens, whether or not impregnated, coated, covered or laminated: Of man-made filaments: Weighing more than 150 g/m2: Laminated fabrics.” The rate of duty will be Free. 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/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (“CFR”), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (“CBP”) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 CFR 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 Michael Capanna at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division
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