July 23 CBP Bulletin Proposes to Revoke Ruling on Conductive Greases
In the July 23 issue of the CBP Customs Bulletin (Vol. 48, No. 29), CBP published notices that propose to revoke a ruling and similar treatment for the tariff classification of conductive greases.
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Comments on Proposals Due Aug. 22
CBP said consideration will be given to any written comments received by Aug. 22 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.)
Proposals
CBP is proposing to revoke the ruling 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.
Thermal Conductive Greases
| Item: Five types of thermal conductive greases imported in the form of organopolysiloxane paste containing aluminum and zinc oxide, together with trade secret ingredients. They are used as thermally conductive pastes in the manufacture of electronic products, such as printed circuit boards and other board-level products for which thermal dissipation is an important feature. They aid in thermal dissipation via a heat sink. They are imported in bulk and either repackaged and sold in bulk, or repackaged into syringes. The products are identified as X23--7783D, G751, X23--7756, X23--7762, and G765, |
| Current: For X23--7783D, G751, X23--7762 and G765: 3824.90.2800, 6.5%, (Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Mixtures containing 5 % or more by weight of one or more aromatic or modified aromatic substances: Other) For X23--7756: 3824.90.7000, Free, (Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other: Electroplating chemical and electroless plating solutions and other materials for printed circuit boards, plastics and metal finishings.) |
| Proposed: For all: 3910.00.00, 3%, (silicones in primary form) |
| Reason: Initial laboratory reports found that X-237783D, G-765, G751, and X23--7762 were thermal conductive greases composed of more than 5% of a proprietary chemical that was an aromatic compound and that X23--7756 was composed of less than 1% of a proprietary chemical that was an aromatic compound. The importer subsequently provided more complete breakdown of the chemicals, which showed that the products are silicone in their primary form. |
| Proposed for revocation: NY N144035 (2011) |
| Proposed new ruling: HQ H192517 |