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Jan 2 CBP Bulletin Proposes to Revoke Rulings on Ballistic Jacket Plates, Thermal Transfer Ribbons

In the Jan. 2 issue of the CBP Customs Bulletin (Vol. 47, No. 52), CBP published two notices that propose to revoke rulings and similar treatment for the tariff classification of ballistic jacket plates and thermal transfer ribbons.

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Comments on Proposed Revocations Due Feb. 3

CBP said consideration will be given to any written comments received by Feb. 3 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 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.)

Proposed Revocations

CBP is proposing to revoke the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke or modify any treatment it has previously accorded to substantially identical transactions.

Brick Type Plate for Ballistic Jackets

Item: Brick Type Plate for Ballistic Jackets. The plates are used for ballistic protection in tactical vests and consists of 98% alumina (a synthetic oxide of aluminum) and 2% other components. It is baked with a fiber glass Kevlar coating which provides its ballistic value.
Current: 6903.20.0000, Free, (Other refractory ceramic goods… Containing by weight more than 50 percent of alumina or of a mixture or compound of alumina and of silica.)
Proposed: 6914.90.80, 5.6%, (Other ceramic articles: Other: Other)
Reason: While the plates can withstand temperatures of 1,500 degrees Celsius and higher, as required in heading 6903, because high heat exposure will not be a common part of the merchandise's use, that heading is wrong, said CBP. Since the plates are excluded from that and other headings, CBP finds the plates fit the broad range of merchandise that CBP has classified in heading 6914.
Proposed for revocation: NY N016133 (2007)
Proposed new ruling: HQ H218236

Thermal Transfer Ribbons

Item: Thermal Transfer Ribbons. The ribbons are attached with other components to a spool in a free trade zone and are designed to be used solely on dye sublimation printers. The printers are said to be capable of being connected to an automated data processor or network.
Current: 8443.99.2550, Free, (Printing machinery…: parts and accessories: other: other: other.)
Proposed: Imported with a width not exceeding 105 mm, 3702.39.01, 3.7% (Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles; instant print film in rolls, sensitized, unexposed: Other film, without perforations, of a width not exceeding 105 mm: Other.)

Imported in a width exceeding 105 mm, 3702.44.01, 3.7% (Photographic film in rolls, sensitized, unexposed, of any material other than paper, paperboard or textiles; instant print film in rolls, sensitized, unexposed: Other film, without perforations, of a width exceeding 105 mm: Of a width exceeding 105 mm but not exceeding 610 mm)

Reason: Heading 3702 is more specific than heading 8443
Proposed for revocation: NY N022500 (2008)
Proposed new ruling: HQ H097674