N353667

N353667 September 25, 2025 CLA-2-39:OT:RR:NC:N5:137 CATEGORY: Classification TARIFF NO.: 3824.99.2900, 9903.01.32; 3907.29.0000, 3907.99.5050, 9903.02.56 Doowon Choi SEJU Customs Corporation 602,6, Eonju-ro 141-gil, Gangnam-gu, Seoul, 602, 6, Eonju-ro 141-gil, Gangnam-gu Seoul 06050 South Korea RE: The tariff classification of Miramer AS2010, Miramer AS4004 and Miramer PE250 from South Korea Dear Mr. Choi: In your letter dated September 12, 2025, you requested a tariff classification ruling on behalf of your client, Miwon Specialty Chemical Co., Ltd. Miramer AS2010 (CAS No. 67906-98-3) is a polyester acrylate copolymer. It is used in the manufacture of coatings and inks. Miramer AS4004 (CAS No. 2133807-72-2) is a polyether acrylate copolymer. It is used in the manufacture of coatings and inks. Miramer PE250 (CAS No. 36425-15-7) is a combination of Bisphenol A diglycidyl ether resin and Methacrylic acid. It is used in the manufacture of 3D printing, adhesives and inks. You suggest classification of the Miramer PE250 in subheading 3824.99.9397, HTSUS, which provides for 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: Other Other: Other. We disagree. Because the Bisphenol A diglycidyl ether resin component is more than 5 percent by weight of aromatic substances, it cannot be classified under that subheading. The applicable subheading for the Miramer AS2010 will be 3907.90.5050, HTSUS, which provides for polyacetals, other polyethers and epoxide resins, in primary forms; polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms: other polyesters: other: other: other. The general rate of duty will be 6.5 percent ad valorem. The applicable subheading for the Miramer AS4004 will be 3907.29.0000, HTSUS, which provides for polyacetals, other polyethers and epoxide resins, in primary forms; polycarbonates, alkyd resins, polyallyl esters and other polyesters, in primary forms: other polyethers: other. The general rate of duty will be 6.5 percent ad valorem. The applicable subheading for the Miramer PE250 will be 3824.99.2900, HTSUS, which provides for 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: Mixtures containing 5 percent or more by weight of one or more aromatic or modified aromatic substances: Other. The general rate of duty will be 6.5 percent ad valorem. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of South Korea will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading 3907.29.0000 or 3907.90.5050, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of South Korea will be subject to an additional ad valorem rate of duty of 15 percent. The Miramer PE250 falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 3824.99.2900, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Christina Allen at julie.c.allen@cbp.dhs.gov. 
Sincerely,
 (for) 

Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division