The tariff classification of adhesives from Canada

N258215 November 10, 2014 CLA-2-39:OT:RR:NC:N2:421 CATEGORY: Classification TARIFF NO.: 3904.21.0000; 3909.50.5000 Mr. Greg Chevalier Argyle Customs and Forwarding 1410 W. Ganson Street Jackson, MI 49202 RE: The tariff classification of adhesives from Canada Dear Mr. Chevalier: In your letter dated October 14, 2014, on behalf of Duro-Last Roofing Inc., you requested a tariff classification ruling. You provided information on two types of adhesives. Duro-Last Waterborne II Adhesive is described as a waterborne adhesive used to bond Duro-Last Membrane and Duro-Fleece Membrane to a variety of substrates on both horizontal and vertical services. It is imported in a five gallon pail. At a weight of 9 pounds per gallon, the weight of the imported pail is 45 pounds. You identify the ingredients as polyvinyl chloride (PVC) with small amounts of toluene, titanium dioxide and methanol. Duro-Last Insta-Stik Professional Insulation Adhesive is described as a moisture cured adhesive. It is a single component polyurethane adhesive foam dispensed from a portable disposable pressurized container that requires no external power source. Each container weighs 30 pounds in gross weight and 23 pounds in net chemical weight. The container incorporates a flexible dispensable hose and wand assembly with an on/off ball valve at the end of the dispensing hose to allow for single hand application. Insta-Stik Insulation Adhesive is used to attach roof insulation boards to roof decks and substrates in new roof and roof replacement applications. You identify the ingredients as diphenylmethane diisocyanate, isomers and homologues, with foam blowing agents. The applicable subheading for the Duro-Last Waterborne II PVC adhesive will be 3904.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for polymers of vinyl chloride or of other halogenated olefins, in primary forms: other poly(vinyl chloride): nonplasticized.. The general rate of duty will be 6.5 percent ad valorem. The applicable subheading for the Duro-Last Insta-Stik Professional Insulation Polyurethane Adhesive will be 3909.50.5000, HTSUS, which provides for polyurethanes: other. The general rate of duty will be 6.3 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 Joan Mazzola at joan.m.mazzola@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division