The tariff classification of PEDILASTIK and PEDILASTIK-Vfrom Spain.

NY 876767 August 7, 1992 CLA-2-30:S:N:N1-F:238 876767 CATEGORY: Classification TARIFF NO.: 3005.10.5000 Gregoria Sanchez, Esq. 330 East 39th Street New York, NY 10016 RE: The tariff classification of PEDILASTIK and PEDILASTIK-V from Spain. Dear Ms. Sanchez: In your letter dated July 20, 1992, on behalf of your client, Dr. Evaristo Rodriguez Valverde, you requested a tariff classification ruling. The submitted samples, PEDILASTIK and PEDILASTIK-V, are non- medicated foot-care products used in the treatment of such ailments as plantar warts, calluses, bursitis, and pain in the sole of the foot. They are composed of a silicone material, which is soft, smooth and tacky to the touch, and have an adhesive layer on one side. Because of its density, the material works as a cushion. The material is used by cutting it to the desired shape and size, and then applying it, like a dressing, to the affected area on the foot. The side opposite the adhesive layer is the side that actually comes into contact with the skin. The material is held in place by strips of adhesive tape (not supplied), which are placed over the material's own adhesive (outer) layer. Both products are put up in the form of individual packages, each of which contains a 10cm. x 30cm. piece of the material. In a conversation with a member of my staff, on August 5, 1992, you stated that both products are exclusively intended for sale directly, without repacking, to users (physicians, pharmacies, etc.) for medical purposes. The applicable subheading for both products will be 3005.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for wadding, gauze, bandages and similar articles (for example, dressings, ... ), ... put up in forms or packings for retail sale for medical, surgical, dental or veterinary purposes: adhesive dressings and other articles having an adhesive layer: other. The rate of duty will be 7 percent ad valorem. This merchandise may be subject to the regulations of the Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number (202) 443-3380. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport