July 6 CBP Bulletin Proposes To Revoke Rulings on Fragrance Chemical, Thermal Transfer Ribbons
In the July 6 issue of the CBP Customs Bulletin (Vol. 50, No. 27) (here), CBP published notices that propose to revoke or modify rulings and similar treatment for the classification of Galaxolide mixtures, thermal transfer ribbons.
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Comments on Proposals Due Aug. 5
CBP said consideration will be given to any written comments received by Aug. 5 before taking this action. In addition, any party who has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Galaxolide Mixtures
| Item: Chemical mixtures used in the fragrance industry |
| Current: 2932.99.7000, 6.5%, “Heterocyclic compounds with oxygen hetero-atom(s) only: Other: Other: Aromatic: Other: Other." |
| Proposed: 3302.90.1050, Free, “Mixtures of odoriferous substances and mixtures (including alcoholic solutions) with a basis of one or more of these substances, of a kind used as raw materials in industry; other preparations based on odoriferous substances, of a kind used for the manufacture of beverages: Other: Containing no alcohol or not over 10 percent of alcohol by weight: Other.” |
| Reason: Because the products are mixtures consisting of an odoriferous substance and diluents, and because they are used as raw materials for perfumery products, they are described by EN 33.02 as examples of products classifiable in heading 3302, CBP said. |
| Proposed for revocation: NY N196797 (2012), NY C85217 (2008) |
| Proposed new ruling: HQ H274972 |
Thermal Transfer Ribbons
| Item: Ink ribbons for printing. |
| Current: 9612.10.10, 2.9%, "Typewriter or similar ribbons, inked or otherwise prepared for giving impressions, whether or not on spools or in cartridges; ink pads, whether or not inked, with or without boxes: [r]ibbons: [m]easuring less than 30 mm in width, permanently put up in plastic or metal cartridges (whether or not containing spools) of a kind used in typewriters, automatic data processing or other machines. . . .” |
| Proposed: 8443.99.25, Free, “Printing machinery used for printing by means of plates, cylinders and other printing components of heading 8442; other printers, copying machines and facsimile machines, whether or not combined; parts and accessories thereof: Parts and accessories: Other: Parts and accessories of printers: Other.” |
| Reason: Unlike typewriters, the ribbons function as a medium for printing images onto various media by way of heat, CBP said. The thermal transfer ribbons meet the definition of “parts” as defined by the courts because they are integral part of a printing machine without which the machine could not function and are best classified in heading 8443. |
| Proposed for revocation: HQ 958572 (1996), HQ 958899 (1996), NY 814940 (1995), NY 814490 (1995) |
| Proposed new ruling: HQ H262583 |