WEBVTT 00:00:03.870 --> 00:00:04.718 >> NICOIS HARRIS: Good afternoon. 00:00:04.719 --> 00:00:08.374 I am Nicois Harris with CBP's Office of Trade Relations. 00:00:08.375 --> 00:00:13.923 Today's webinar is on Polymers, Copolymers and Primary Forms...Oh My! 00:00:13.924 --> 00:00:19.218 This webinar is part of the NCSD's 2024 webinar series. 00:00:19.219 --> 00:00:23.622 Please be mindful that you will be on mute during this presentation. 00:00:23.623 --> 00:00:26.759 Therefore, we ask that you please submit any questions 00:00:26.760 --> 00:00:29.561 you have within the chat feature. 00:00:29.562 --> 00:00:33.399 If you plan to request the optional CCS or CES 00:00:33.400 --> 00:00:39.039 credits through the NCBFAA Educational Institute, 00:00:39.572 --> 00:00:42.908 please check the chat box for the completion code. 00:00:42.909 --> 00:00:46.879 It will be provided several times throughout the webinar. 00:00:46.880 --> 00:00:51.091 Now, I'd like to pass it on over to National Import Specialist, 00:00:51.092 --> 00:00:52.772 Ms. Christina Allen. 00:00:55.422 --> 00:00:57.056 >> CHRISTINA ALLEN: Good afternoon. 00:00:57.057 --> 00:00:58.757 My name is Christina Allen. 00:00:58.758 --> 00:01:03.363 As Ms. Harris said, I am National Import Specialist 137. 00:01:03.863 --> 00:01:08.934 I currently handle Chapter 26, which are ores, slags, and ash. 00:01:08.935 --> 00:01:13.639 Chapter 27, mineral fuels, oils, products of their distillation, 00:01:13.640 --> 00:01:17.186 bituminous substances, and mineral waxes. 00:01:17.210 --> 00:01:20.547 Heading 3826, which is biodiesel. 00:01:20.680 --> 00:01:25.350 Headings 3901 through 3923 and 3925, 00:01:25.351 --> 00:01:30.122 which are polymers and primary forms and various articles of plastic. 00:01:30.123 --> 00:01:34.526 Headings 4001 through 4010 and 4016, 00:01:34.527 --> 00:01:38.497 which are rubber and primary forms and articles of rubber. 00:01:38.498 --> 00:01:41.266 My topic today is entitled Polymers, 00:01:41.267 --> 00:01:44.736 Copolymers and Primary Forms...Oh My! 00:01:44.737 --> 00:01:49.808 It is going to concentrate within the headings of 3901 to 3914, 00:01:49.809 --> 00:01:52.955 which is for polymers in primary form. 00:01:52.979 --> 00:01:57.898 I understand that polymers can be very complicated to classify, 00:01:58.885 --> 00:02:03.088 so I'm going to discuss some basic characteristics of polymers. 00:02:03.089 --> 00:02:06.692 I'm going to elaborate on the chapter notes that are related 00:02:06.693 --> 00:02:11.574 to those headings in the Harmonized Tariff Schedule of the US. 00:02:11.598 --> 00:02:12.798 Finally, I'm going to discuss 00:02:12.799 --> 00:02:16.268 the information that will be necessary in order to determine 00:02:16.269 --> 00:02:19.681 the proper classification of these polymers. 00:02:20.073 --> 00:02:22.141 As was stated previously, 00:02:22.142 --> 00:02:25.310 I ask that all questions are entered into the chat box. 00:02:25.311 --> 00:02:28.046 I will take a few short pauses 00:02:28.047 --> 00:02:32.014 within the presentation to address a few questions. 00:02:32.118 --> 00:02:34.553 We'll finish questions at the end. 00:02:34.554 --> 00:02:39.424 I do have one request and that is due to the complex nature of polymers, 00:02:39.425 --> 00:02:43.562 I do ask that you not ask questions regarding 00:02:43.563 --> 00:02:49.469 the classification of specific products during this presentation. 00:02:56.295 --> 00:02:58.343 >> CHRISTINA: This is CBP's mission statement, 00:02:58.344 --> 00:03:01.647 to protect the American people, safeguard our borders, 00:03:01.648 --> 00:03:04.349 and enhance the nation's economic prosperity. 00:03:04.350 --> 00:03:06.639 The Office of Trade's mission statement is, 00:03:06.640 --> 00:03:10.589 "The Office of Trade facilitates legitimate trade, enforces US laws, 00:03:10.590 --> 00:03:14.426 and protects the American economy to ensure consumer safety 00:03:14.427 --> 00:03:18.949 and create a level playing field for American businesses." 00:03:19.699 --> 00:03:24.570 Just a couple of quick disclaimers basically that this webinar 00:03:24.571 --> 00:03:27.639 is for general information purposes intended 00:03:27.640 --> 00:03:30.052 to provide guidance and information. 00:03:30.053 --> 00:03:32.811 Reliance solely on the information in this webinar 00:03:32.812 --> 00:03:36.082 may not be considered reasonable care. 00:03:38.117 --> 00:03:42.955 Any audiovisual media in this webinar is either public 00:03:42.956 --> 00:03:45.958 domain or obtained through proper copyright licenses. 00:03:45.959 --> 00:03:49.261 Further copying and distribution of copyrighted materials 00:03:49.262 --> 00:03:53.070 may require permission from the original creator. 00:03:53.967 --> 00:03:55.133 For binding ruling requests, 00:03:55.134 --> 00:04:01.173 this is the link to our eRuling's module 00:04:01.174 --> 00:04:05.845 to request for electronic binding rulings. 00:04:10.283 --> 00:04:11.641 Let's get started. 00:04:11.908 --> 00:04:13.643 So what is a polymer? 00:04:14.187 --> 00:04:19.027 The name "polymer" is derived from the Greek word "polumeros." 00:04:19.493 --> 00:04:24.095 "Polu," meaning many, and "meros," meaning a share or part. 00:04:24.264 --> 00:04:28.201 Together, it means many parts. 00:04:30.169 --> 00:04:34.006 The simplest definition of polymer is a long chain 00:04:34.007 --> 00:04:40.146 formed by joining many smaller molecules, which are called monomers. 00:04:43.016 --> 00:04:48.420 A monomer is the basic unit that has the ability to bind with other units. 00:04:48.421 --> 00:04:52.924 A very simplified way to understand a monomer is to picture 00:04:52.925 --> 00:04:56.728 a set of beads that are designed to lock together. 00:04:56.729 --> 00:05:00.599 Each individual bead is an item on its own, 00:05:00.600 --> 00:05:03.435 but it can also snap together with other beads 00:05:03.436 --> 00:05:06.372 to form something entirely different. 00:05:08.341 --> 00:05:13.646 Polymerization is the process by which polymers are formed. 00:05:14.013 --> 00:05:17.349 It results from the carbon-to-carbon bonding 00:05:17.350 --> 00:05:21.079 of monomer units that form the polymer backbone. 00:05:21.421 --> 00:05:25.257 If you just think back to our previous illustration 00:05:25.258 --> 00:05:28.160 on the previous slide of the interlocking beads, 00:05:28.161 --> 00:05:33.333 that's a very simplified illustration of polymerization. 00:05:35.401 --> 00:05:39.381 In nature, polymerization occurs spontaneously. 00:05:39.405 --> 00:05:44.678 For example, sugar is a long-chain polysaccharide. 00:05:45.978 --> 00:05:50.015 Industrially, synthetic polymers are formed from monomers 00:05:50.016 --> 00:05:54.553 via an assorted combination of heat, catalysts, and pressure. 00:05:54.554 --> 00:05:56.588 The diagram on the slide shows 00:05:56.589 --> 00:05:59.124 the polymerization of an unknown number 00:05:59.125 --> 00:06:02.694 of ethylene monomers that have been subjected to heat, 00:06:02.695 --> 00:06:05.517 pressure, and catalysts, which in turn 00:06:05.518 --> 00:06:10.002 polymerizes those ethylene monomers into polyethylene. 00:06:17.710 --> 00:06:19.378 >> CHRISTINA: As I said in the introduction, 00:06:19.379 --> 00:06:23.582 our presentation is going to focus on the polymers in primary forms 00:06:23.583 --> 00:06:27.353 as classified in Headings 3901 to 3914. 00:06:28.378 --> 00:06:34.292 Headings 3901 through 3911 cover polymers obtained by chemical synthesis. 00:06:35.255 --> 00:06:40.799 Headings 3912 through 3913 are our natural polymers or polymers 00:06:40.800 --> 00:06:44.284 obtained from natural polymers by chemical treatment. 00:06:44.285 --> 00:06:52.612 3914 covers ion exchangers based on the polymers of Headings 3901 to 3913. 00:06:59.051 --> 00:07:03.255 Note 3 to Chapter 39 is where we get the guidelines that are required 00:07:03.256 --> 00:07:08.260 for classification as a polymer in the Headings 3901 to 3911 00:07:08.261 --> 00:07:11.911 or the polymers obtained by chemical synthesis. 00:07:12.999 --> 00:07:15.634 They fall into specific categories. 00:07:15.635 --> 00:07:18.888 The first is liquid synthetic polyolefins, 00:07:19.071 --> 00:07:22.374 of which less than 60% by volume distills 00:07:22.375 --> 00:07:26.388 at 300 degrees Celsius after conversion 00:07:26.389 --> 00:07:29.614 to 1,013 millibars when a reduced pressure 00:07:29.615 --> 00:07:31.216 distillation method is used. 00:07:31.217 --> 00:07:35.455 This applies to Headings 3901 and 3902. 00:07:36.722 --> 00:07:38.890 You have resins that are not highly polymerized 00:07:38.891 --> 00:07:41.193 of the coumarone-indene type. 00:07:41.194 --> 00:07:43.756 Those would be in Heading 3911. 00:07:45.398 --> 00:07:50.512 Other synthetic polymers with an average of at least five monomer units, 00:07:50.536 --> 00:07:56.108 silicones, which are in 3910, resols in 3909, and other pre-polymers. 00:07:57.443 --> 00:08:02.247 If an item does not meet these criteria, 00:08:02.248 --> 00:08:08.400 then it is not a polymer classified in Headings 3901 through 3911. 00:08:19.131 --> 00:08:21.858 The liquid synthetic polyolefins, 00:08:22.235 --> 00:08:25.704 and I'm not going to read that whole long thing again to you, 00:08:25.705 --> 00:08:28.674 but basically, these are polymers obtained from ethylene, 00:08:28.675 --> 00:08:32.111 propene, butenes, and other olefins. 00:08:32.311 --> 00:08:35.914 Olefin is another word for alkene, 00:08:35.915 --> 00:08:38.917 which is where one or more pairs of carbon 00:08:38.918 --> 00:08:42.121 atoms are linked by a double bond. 00:08:43.589 --> 00:08:46.604 With the resins not highly polymerized, 00:08:47.460 --> 00:08:51.029 they are obtained by the copolymerization of mixed 00:08:51.030 --> 00:08:54.699 monomers, including coumarone or indene, 00:08:54.700 --> 00:08:57.870 which are derived from coal tar. 00:09:03.609 --> 00:09:07.312 Other synthetic polymers with an average of at least five monomer units. 00:09:07.313 --> 00:09:10.081 I get asked about this quite frequently, 00:09:10.082 --> 00:09:13.718 so this diagram on the slide does illustrate that. 00:09:13.719 --> 00:09:18.089 In this diagram, a number of monomer units are introduced to catalysts, 00:09:18.090 --> 00:09:22.160 heat, and pressure, which results in a chain that contains 00:09:22.161 --> 00:09:24.723 a number of repeating monomers. 00:09:26.499 --> 00:09:30.969 Individual monomer is represented by a monomer who is bracketed 00:09:30.970 --> 00:09:34.506 and the repeating monomers is represented by N. 00:09:34.507 --> 00:09:40.328 If you ever submit a request for classification of a polymer 00:09:40.352 --> 00:09:45.817 and my office asks you to provide the average number 00:09:45.818 --> 00:09:47.452 of repeating monomer units, 00:09:47.453 --> 00:09:51.690 we are looking for that N value to know 00:09:51.691 --> 00:09:57.063 how many monomer units are repeating in that polymer. 00:09:58.798 --> 00:10:01.433 Silicones, we're going to go into further detail later 00:10:01.434 --> 00:10:05.956 in the presentation when we cover the individual polymers. 00:10:06.439 --> 00:10:07.672 Same with resols, 00:10:07.673 --> 00:10:12.811 but pre-polymers are characterized by some repetition 00:10:12.812 --> 00:10:17.216 of monomer units and may contain unreacted monomers. 00:10:17.717 --> 00:10:22.154 Pre-polymers are not normally used in this pre-polymer 00:10:22.688 --> 00:10:26.559 form but are intended to be further polymerized. 00:10:28.361 --> 00:10:33.439 The term does not cover finished products such as diisobutylenes, 00:10:34.734 --> 00:10:38.638 which would be in Heading 2710. 00:10:49.682 --> 00:10:54.052 Note 4 to Chapter 39 actually defines a copolymer for us. 00:10:54.053 --> 00:10:59.624 It is all polymers in which no single monomer unit contributes 00:10:59.625 --> 00:11:05.197 95% or more by weight to the total polymer content. 00:11:05.398 --> 00:11:12.204 Simply put, it is a polymer made by a reaction of two different monomers. 00:11:15.975 --> 00:11:18.372 For copolymer classification, 00:11:18.944 --> 00:11:21.880 except where the context otherwise requires, 00:11:21.881 --> 00:11:26.851 copolymers and polymer blends are classified by the comonomer unit 00:11:26.852 --> 00:11:32.792 which predominates by weight over all the other single comonomer units. 00:11:34.007 --> 00:11:35.427 Constituent comonomer units that fall 00:11:35.428 --> 00:11:37.495 within the same heading are taken together. 00:11:37.496 --> 00:11:45.870 For example, if you had a copolymer that consists of 45% ethylene, 00:11:46.472 --> 00:11:52.144 35% propylene, and 20% isobutylene monomer units. 00:11:52.282 --> 00:11:58.150 Okay, so propylene and isobutylene are both classified in 3902. 00:11:59.218 --> 00:12:03.823 Those are considered to be constituent comonomer units. 00:12:04.156 --> 00:12:09.461 When combined, they comprise 55% of the copolymer and, 00:12:09.462 --> 00:12:13.698 therefore, will predominate over the ethylene monomer unit. 00:12:13.699 --> 00:12:19.939 In this case, the copolymer would be classified somewhere in 3902. 00:12:21.540 --> 00:12:25.610 If you don't have a single comonomer unit that predominates, 00:12:25.611 --> 00:12:28.880 then the copolymer or polymer blend is classified 00:12:28.881 --> 00:12:33.586 in the heading that occurs last in numerical order. 00:12:38.591 --> 00:12:41.527 What's a chemically modified polymer? 00:12:43.863 --> 00:12:47.132 It's a polymer where only the appendages to the main polymer 00:12:47.133 --> 00:12:50.941 chain have been changed by the chemical reaction. 00:12:51.070 --> 00:12:53.638 These polymers are classified 00:12:53.639 --> 00:12:58.144 in the heading appropriate to the unmodified polymer. 00:12:58.711 --> 00:13:02.882 This provision does not apply to graft polymers. 00:13:03.182 --> 00:13:06.281 Before you ask, a graft polymer 00:13:06.282 --> 00:13:08.586 is a branched polymer with side chains 00:13:08.587 --> 00:13:13.268 that are composed of different polymers than the main chain. 00:13:21.033 --> 00:13:23.760 If there is an "other" 00:13:25.237 --> 00:13:28.106 in the same series and these are in Subheading 00:13:28.107 --> 00:13:30.367 Note 1(a) and 1(b) 00:13:30.387 --> 00:13:34.775 which are the guidelines for classifying chemically modified polymers. 00:13:35.281 --> 00:13:40.652 If you have an "other" in the series, then the chemically modified polymer 00:13:40.653 --> 00:13:45.123 will be classified in the other subheading 00:13:45.124 --> 00:13:50.462 unless it is more specifically covered by another heading. 00:13:51.263 --> 00:13:57.469 If there is no other provision within that series of subheadings, 00:13:57.603 --> 00:14:01.840 the classification will default back to the Note 5 rules, 00:14:01.841 --> 00:14:04.175 and then it would go and be classified 00:14:04.176 --> 00:14:08.540 to the subheading appropriate to its unmodified polymer. 00:14:14.954 --> 00:14:18.363 Like I said, I call these the polymers of primary forms 00:14:18.364 --> 00:14:21.260 in Headings 3901 to 3914. 00:14:22.127 --> 00:14:26.173 A lot of questions would be, what is a primary form? 00:14:27.199 --> 00:14:33.671 Note 6 to Chapter 39 actually defines primary forms for us. 00:14:33.672 --> 00:14:37.141 It basically says that the term "primary forms" 00:14:37.142 --> 00:14:40.045 only apply to the following forms. 00:14:40.179 --> 00:14:43.414 Liquids and pastes, including dispersions, emulsions, 00:14:43.415 --> 00:14:45.950 and suspensions, and solutions, 00:14:45.951 --> 00:14:49.721 and blocks of irregular shape, lumps, powders, 00:14:49.722 --> 00:14:51.289 which include molding powders, 00:14:51.290 --> 00:14:55.261 granules, flakes, and similar bulk forms. 00:14:59.598 --> 00:15:01.366 In a liquid and paste, 00:15:01.367 --> 00:15:04.302 it can be the basic polymer which requires curing 00:15:04.303 --> 00:15:08.039 by heat or other means to form a finished material, 00:15:08.040 --> 00:15:09.974 or it can be a dispersion or solutions 00:15:09.975 --> 00:15:15.781 of uncured or partially cured materials. 00:15:18.417 --> 00:15:19.984 These liquids may contain 00:15:19.985 --> 00:15:23.554 other materials that are intended to give the finished product 00:15:23.555 --> 00:15:28.426 special physical properties or other desirable characteristics. 00:15:28.427 --> 00:15:31.896 Some of these materials could include plasticizers, 00:15:31.897 --> 00:15:36.702 stabilizers, fillers, coloring matter. 00:15:38.404 --> 00:15:43.608 However, when as a result of the addition of certain substances, 00:15:43.609 --> 00:15:47.879 the new product answers to a description in a more specific 00:15:47.880 --> 00:15:51.149 heading elsewhere in the nomenclature, 00:15:51.150 --> 00:15:54.553 then those are excluded from Chapter 39. 00:15:56.257 --> 00:15:58.075 One is prepared glues. 00:15:58.624 --> 00:16:02.783 It's basically explained more clearly 00:16:02.784 --> 00:16:07.366 in Exclusion B at the end of the general explanatory note. 00:16:07.733 --> 00:16:11.469 Preparations that are specially formulated for use as adhesive 00:16:11.470 --> 00:16:17.109 that consist of polymers or blends of Headings 3901 to 3913, 00:16:18.110 --> 00:16:20.378 which, apart from permitted additions, 00:16:20.379 --> 00:16:24.015 contain other added substances like waxes, 00:16:24.016 --> 00:16:27.585 rosin esters, unmodified natural shellac. 00:16:27.586 --> 00:16:29.989 Those are excluded. 00:16:30.422 --> 00:16:37.069 Also, products of Headings 3901 to 3913 put up for retail sale as glues 00:16:37.070 --> 00:16:42.468 or adhesives that do not exceed a net weight of 1 kilogram. 00:16:43.168 --> 00:16:45.565 Those are classified in 3506. 00:16:46.538 --> 00:16:51.933 Prepared additives for mineral oils are typically classified in 3811. 00:16:52.378 --> 00:16:53.913 Solutions 00:16:55.812 --> 00:16:58.516 other than collodions consisting 00:16:58.517 --> 00:17:05.223 of any of those products from 3901 to 3913 in volatile organic solvents 00:17:05.224 --> 00:17:10.469 when the weight of the solvent exceeds 50% of the weight of the solution, 00:17:10.596 --> 00:17:13.131 those would be excluded from this chapter. 00:17:13.132 --> 00:17:16.702 They fall in Heading 3208. 00:17:17.403 --> 00:17:23.742 That exclusion is noted in Note 2(e) to Chapter 39. 00:17:25.377 --> 00:17:28.256 Liquid polymers without a solvent, 00:17:28.280 --> 00:17:31.338 if they are clearly identifiable as being intended 00:17:31.339 --> 00:17:35.265 for use solely as varnishes in which the formation 00:17:35.289 --> 00:17:39.157 of the film depends on heat, atmospheric humidity, or oxygen 00:17:39.158 --> 00:17:41.759 and not on the addition of a hardener, 00:17:41.760 --> 00:17:44.163 would be classified in 3210. 00:17:47.132 --> 00:17:52.671 Polymers in primary forms that are further formulated with additives, 00:17:52.805 --> 00:17:57.475 which make the product suitable for the expressed use as a mastic, 00:17:57.476 --> 00:17:59.978 would be classified in 3214. 00:18:05.250 --> 00:18:09.854 Powders, granules, and flakes may consist of unplasticized materials, 00:18:09.855 --> 00:18:13.624 which can become plastic in the molding and curing process, 00:18:13.625 --> 00:18:17.963 or of materials to which plasticizers have been added. 00:18:18.197 --> 00:18:21.207 They may incorporate fillers, 00:18:21.817 --> 00:18:25.437 which could be wood flour, cellulose, 00:18:25.704 --> 00:18:29.807 textile fibers, mineral substances, starch, and then, of course, 00:18:29.808 --> 00:18:32.754 coloring matter or other substances. 00:18:32.778 --> 00:18:39.151 Some uses of these are molding, the manufacture of varnishes, glues. 00:18:39.384 --> 00:18:42.796 They can be used as thickeners, flocculants. 00:18:42.921 --> 00:18:45.890 Another thing, powders can be used to coat objects 00:18:45.891 --> 00:18:51.163 by the application of heat with or without static electricity. 00:18:56.602 --> 00:18:58.736 These blocks of irregular shape, lumps, 00:18:58.737 --> 00:19:03.608 and similar bulk forms may contain fillers, coloring matter, 00:19:03.609 --> 00:19:07.713 or other substances that we've previously cited. 00:19:07.946 --> 00:19:12.016 You have to remember, they must be blocks of irregular shape. 00:19:12.017 --> 00:19:17.389 Blocks of regular geometric shapes are not primary forms. 00:19:17.589 --> 00:19:21.959 Another thing to note about primary forms is that waste, parings, 00:19:21.960 --> 00:19:28.032 and scrap of a single thermoplastic material that has been transformed 00:19:28.033 --> 00:19:30.668 into primary forms would be classified 00:19:30.669 --> 00:19:35.514 in their heading within 3901 to 3914, 00:19:35.515 --> 00:19:38.910 according to their material, and they would not be waste, paring, 00:19:38.911 --> 00:19:42.548 and scrap in Heading 3915. 00:19:45.951 --> 00:19:51.690 Okay, so I'm just going to take a moment to see if we have any questions. 00:19:53.692 --> 00:19:55.393 Just for a brief moment because I know 00:19:55.394 --> 00:19:57.873 that was a lot of information. 00:19:59.131 --> 00:20:01.966 >> MODERATOR: Not yet. None of them have come in yet. 00:20:01.967 --> 00:20:03.434 >> CHRISTINA: Okay, that's perfect. 00:20:03.435 --> 00:20:05.666 We are going to now move on 00:20:05.964 --> 00:20:10.041 to the characteristics of the individual polymers. 00:20:14.646 --> 00:20:16.960 Beginning with Heading 3901, 00:20:17.349 --> 00:20:22.754 it covers polymers of ethylene in primary forms. 00:20:23.522 --> 00:20:26.389 Polyethylene is a translucent material 00:20:26.390 --> 00:20:29.695 that has a wide range of applications. 00:20:31.196 --> 00:20:38.403 It is broken in classification out into low-density polyethylene or LDPE. 00:20:39.338 --> 00:20:43.909 Those low-density polyethylenes have specific gravity 00:20:43.919 --> 00:20:47.479 at 20 degrees Celsius of less than 0.94. 00:20:48.313 --> 00:20:52.383 They're used largely as packaging film, coating, 00:20:52.384 --> 00:20:57.858 and in the manufacture of various household articles, toys, et cetera. 00:20:58.256 --> 00:21:02.475 High-density polyethylene, also known as HDPE, 00:21:03.495 --> 00:21:10.602 has a specific gravity at 20 degrees Celsius of 0.94 or greater. 00:21:11.370 --> 00:21:14.849 It can be used in the manufacture of a variety 00:21:14.850 --> 00:21:17.942 of blow-molded and injection-molded articles, 00:21:17.943 --> 00:21:22.080 woven sacks, containers, pipes, et cetera. 00:21:22.781 --> 00:21:26.083 A thing to remember is that in order to classify 00:21:26.084 --> 00:21:29.654 polyethylenes that are entering into the United States, 00:21:29.655 --> 00:21:33.034 you will need to know the specific gravity 00:21:33.058 --> 00:21:36.061 as well as the intrinsic viscosity. 00:21:40.832 --> 00:21:45.103 Heading 3902 covers the polymers of propylene 00:21:45.871 --> 00:21:48.205 or other olefins in primary forms. 00:21:48.206 --> 00:21:53.196 Basically, it covers the polymers of all the olefins, except ethylene. 00:21:53.812 --> 00:21:58.370 The more important polymers in this heading are polypropylene, 00:21:58.371 --> 00:22:03.219 polyisobutylene, propylene, copolymers. 00:22:04.323 --> 00:22:12.664 With propylene, it has general physical properties that are similar to HDPE. 00:22:13.665 --> 00:22:16.033 It also has a wide range of applications, 00:22:16.034 --> 00:22:20.037 packaging films, molded parts for automobiles, 00:22:20.038 --> 00:22:22.276 coated and laminated products, 00:22:22.277 --> 00:22:25.957 bottles, trays, containers, et cetera. 00:22:30.466 --> 00:22:33.084 Heading 3903 covers polystyrene 00:22:33.085 --> 00:22:37.889 and copolymers of styrene in primary forms. 00:22:38.423 --> 00:22:42.493 Unexpanded polystyrene is a colorless, 00:22:42.494 --> 00:22:45.129 transparent, thermoplastic material. 00:22:45.130 --> 00:22:49.200 It is extensively used in electrical and radio industries, 00:22:49.201 --> 00:22:54.572 packing applications such as foodstuffs and cosmetics. 00:22:54.573 --> 00:22:57.341 It is also used in the manufacture of toys, 00:22:57.342 --> 00:22:59.543 clock cabinets, et cetera. 00:22:59.544 --> 00:23:04.281 Expanded or cellular polystyrene is extensively used 00:23:04.282 --> 00:23:08.152 in thermal insulation for things like refrigerator doors, 00:23:08.153 --> 00:23:11.856 A/C housing, cold storage facilities, 00:23:11.857 --> 00:23:14.458 and in the construction industry. 00:23:14.459 --> 00:23:20.232 It's also used in disposable packaging and in food service articles. 00:23:24.770 --> 00:23:34.179 The important polymers of styrene are styrene-acrylonitrile copolymers or SAN, 00:23:34.713 --> 00:23:39.116 acrylonitrile butadiene styrene, which are ABS copolymers, 00:23:39.117 --> 00:23:42.053 and then styrene-butadiene copolymers. 00:23:42.587 --> 00:23:45.314 Most styrene-butadiene copolymers 00:23:45.624 --> 00:23:49.123 that have substantial amounts of butadiene 00:23:49.124 --> 00:23:53.197 end up complying with Chapter 40 Note 4 00:23:53.198 --> 00:23:56.261 and would be classified as synthetic rubber. 00:23:56.262 --> 00:24:01.372 The SAN copolymers have high tensile strength, 00:24:01.373 --> 00:24:04.041 good moldability, and chemical resistance. 00:24:04.042 --> 00:24:08.045 They're used for making cups, tumblers, refrigerator parts. 00:24:08.046 --> 00:24:12.751 ABS polymers have high shock and weather resistance. 00:24:12.984 --> 00:24:15.719 They are used in manufacture of auto parts, 00:24:15.720 --> 00:24:19.687 refrigerator doors, telephones, bottles, et cetera. 00:24:28.305 --> 00:24:31.444 >> CHRISTINA: Heading 3904 covers the polymers 00:24:31.445 --> 00:24:34.172 of polyvinyl chloride or PVC, 00:24:34.606 --> 00:24:38.375 vinyl chloride copolymers, fluoropolymers, 00:24:38.376 --> 00:24:41.032 and other halogenated olefins. 00:24:42.113 --> 00:24:47.352 PVC, which we've all heard of that, is rigid, colorless material. 00:24:48.854 --> 00:24:51.989 It has limited heat stability and tendency 00:24:51.990 --> 00:24:55.025 to adhere to metallic surfaces when heated. 00:24:55.026 --> 00:24:59.630 With PVC, it's often necessary to add stabilizers, extenders, 00:24:59.631 --> 00:25:04.135 fillers in order to make them useful plastics. 00:25:05.670 --> 00:25:08.005 In their flexible sheet form, 00:25:08.006 --> 00:25:12.878 PVCs are used as waterproof material for curtains, aprons. 00:25:13.178 --> 00:25:15.579 They've been used for high-grade imitation leather 00:25:15.580 --> 00:25:18.912 for upholstery in passenger transportation. 00:25:19.317 --> 00:25:22.586 Rigid PVC is used in the fabrication of pipe, 00:25:22.587 --> 00:25:27.893 covers, ducts, tank linings, and PVC floor tiles. 00:25:30.962 --> 00:25:35.416 One of the most important fluoropolymers 00:25:35.934 --> 00:25:39.795 is polytetrafluoroethylene or PTFE. 00:25:40.705 --> 00:25:43.908 It has wide-ranging applications in electrical, 00:25:43.909 --> 00:25:47.312 chemical, and engineering industries. 00:25:47.546 --> 00:25:49.847 Because it has a high working temperature, 00:25:49.848 --> 00:25:53.251 it is an excellent insulating material. 00:25:53.785 --> 00:25:56.787 Due to its resistance to chemicals, 00:25:56.788 --> 00:26:00.200 it's considered to be almost indestructible. 00:26:02.761 --> 00:26:09.111 A thing to note is that PTFE resin 00:26:09.771 --> 00:26:12.803 from India and Russia are subject 00:26:12.804 --> 00:26:15.306 to anti-dumping and countervailing duties. 00:26:15.307 --> 00:26:20.687 The cases for India are A-533-899 00:26:21.107 --> 00:26:23.925 and C-533-900. 00:26:23.949 --> 00:26:28.110 The cases for Russia are A-462-829 00:26:28.789 --> 00:26:32.129 and C-462-830. 00:26:38.730 --> 00:26:47.441 Heading 3905 is the polymers of vinyl acetate or other vinyl esters 00:26:47.461 --> 00:26:50.674 in primary forms and other vinyl polymers in primary forms. 00:26:50.675 --> 00:26:53.978 Basically, this covers all the vinyl polymers 00:26:53.979 --> 00:26:56.915 that were not covered in Heading 3904. 00:26:58.917 --> 00:27:01.552 A vinyl polymer is one whose monomer 00:27:01.553 --> 00:27:06.658 has the formula that you see on the screen in the diagram. 00:27:06.858 --> 00:27:16.884 That is where the C to whatever the X is. 00:27:17.135 --> 00:27:22.774 It could be many different types of chemicals. 00:27:24.876 --> 00:27:30.081 It cannot be a carbon-to-carbon bond or a carbon-to-hydrogen bond. 00:27:30.649 --> 00:27:33.784 Then another thing to know is that a polyvinyl ketone 00:27:33.785 --> 00:27:37.655 where that C-X bond is a carbon-to-carbon bond, 00:27:37.656 --> 00:27:41.893 they are excluded and they are classified in 3911. 00:27:44.295 --> 00:27:47.674 Polymers of vinyl acetate or other vinyl esters 00:27:47.675 --> 00:27:51.402 are not suitable for the manufacture of articles 00:27:51.403 --> 00:27:54.448 because they are too soft and elastic. 00:27:54.472 --> 00:27:58.642 They are generally used in the preparation of lacquers, 00:27:58.643 --> 00:28:01.040 paints, adhesives, et cetera. 00:28:09.854 --> 00:28:14.091 Polyvinyl alcohol or PVA is classified in 3905. 00:28:14.092 --> 00:28:18.297 It is prepared by the hydrolysis of polyvinyl acetate. 00:28:18.463 --> 00:28:21.031 It comes available in a number of grades, 00:28:21.032 --> 00:28:27.472 depending on the content of the unhydrolyzed vinyl acetate groups. 00:28:29.340 --> 00:28:34.011 These would make excellent emulsifiers and dispersing agents. 00:28:34.012 --> 00:28:36.480 They can be used as protective colloids, 00:28:36.481 --> 00:28:39.650 adhesives, binders, and thickeners in paint, 00:28:39.651 --> 00:28:42.825 pharmaceuticals, cosmetics, and textiles. 00:28:43.321 --> 00:28:46.924 Important to note is that polyvinyl alcohol 00:28:46.925 --> 00:28:51.228 from China and Japan are subject to anti-dumping duties. 00:28:51.229 --> 00:28:55.205 The case from China is for A-570-879 00:28:55.566 --> 00:29:00.094 and the case for Japan is A-588-861. 00:29:08.313 --> 00:29:10.432 Heading 3906 covers 00:29:10.433 --> 00:29:13.784 the polymers of acrylic or methacrylic acid, 00:29:13.785 --> 00:29:15.285 of their salts or esters, 00:29:15.286 --> 00:29:19.600 or of the corresponding aldehydes, amides, or nitriles. 00:29:19.624 --> 00:29:23.660 Probably, the most important is poly(methyl methacrylate). 00:29:23.661 --> 00:29:27.397 It has excellent optical properties, physical strength. 00:29:27.398 --> 00:29:30.043 It's used as a glazing material. 00:29:30.368 --> 00:29:32.736 It's used in outdoor signs and display articles. 00:29:32.737 --> 00:29:35.539 It's been used in the manufacture of artificial eyes, 00:29:35.540 --> 00:29:38.634 contact lenses, and artificial dentures. 00:29:40.044 --> 00:29:46.084 This heading excludes acrylic polymers, which are used as ion exchangers. 00:29:46.684 --> 00:29:51.221 Another thing to note is that copolymers of acrylonitrile, 00:29:51.222 --> 00:29:55.793 which comply with the requirements of Note 4 to Chapter 40, 00:29:55.794 --> 00:29:58.128 are excluded from classification here 00:29:58.129 --> 00:30:02.167 and are instead classified in Chapter 40. 00:30:07.338 --> 00:30:11.603 Heading 3907 has our polyacetals, other polyethers, 00:30:11.604 --> 00:30:13.477 epoxide resins in primary forms. 00:30:13.478 --> 00:30:16.513 These polyacetals are used in engineered 00:30:16.514 --> 00:30:19.950 plastics in things such as ring bearings, 00:30:19.951 --> 00:30:23.097 cams, automotive instrument housing. 00:30:23.121 --> 00:30:26.023 Other polyethers, some of the important ones 00:30:26.024 --> 00:30:32.130 are polyphenylene oxide, which is an engineering plastic. 00:30:33.298 --> 00:30:36.066 Polyoxypropylene, which is used 00:30:36.067 --> 00:30:39.241 as an intermediate for polyurethane foam. 00:30:39.571 --> 00:30:42.873 Epoxide resins, which are used as surface coatings, 00:30:42.874 --> 00:30:46.077 adhesives, molding, casting resins. 00:30:47.078 --> 00:30:55.552 Also in 3907 are our polycarbonates, alkyd resins, polyallyl esters, 00:30:55.553 --> 00:30:58.339 and other polyesters in primary forms. 00:30:58.340 --> 00:31:02.159 Polycarbonates have industrial applications 00:31:02.160 --> 00:31:04.507 such as molding and glazing. 00:31:04.531 --> 00:31:06.569 Alkyd resins are used mainly 00:31:06.570 --> 00:31:10.168 as coatings and in high-grade varnishes. 00:31:11.363 --> 00:31:15.306 Polyallyl esters are used in laminating adhesives, 00:31:16.908 --> 00:31:18.891 coatings, and varnishes. 00:31:23.028 --> 00:31:29.477 A very important product classified in 3907 00:31:29.478 --> 00:31:35.260 is polyethylene terephthalate, known as PET. 00:31:37.003 --> 00:31:40.264 It's used in textiles, packaging films, recording tapes, 00:31:40.265 --> 00:31:42.460 soft drink bottles. 00:31:43.034 --> 00:31:47.167 Usually, the PET that has a viscosity number greater 00:31:47.168 --> 00:31:52.709 than 0.78 milliliters per gram or higher, usually, 00:31:52.710 --> 00:31:56.046 that's what's used for the production of bottles. 00:31:56.047 --> 00:31:58.782 For classification of these products, 00:31:58.783 --> 00:32:01.985 you will need to know the viscosity number. 00:32:01.986 --> 00:32:07.658 To be noted is that PET resin from China and India are subject 00:32:07.659 --> 00:32:11.129 to anti-dumping and countervailing duties. 00:32:11.329 --> 00:32:19.198 China's cases are A-570-024 and C-570-025. 00:32:19.507 --> 00:32:26.294 India is A-533-861 and C-533-862. 00:32:27.512 --> 00:32:33.584 PET resin from Canada and Oman are also subject to anti-dumping duties. 00:32:33.818 --> 00:32:37.794 The case for Canada is A-122-855 00:32:37.814 --> 00:32:43.096 and the case for Oman is A-523-810. 00:32:50.501 --> 00:32:52.836 There's been a great push in recent years towards 00:32:52.837 --> 00:32:57.201 the production of biodegradable alternatives to plastic. 00:32:57.475 --> 00:33:00.490 There are a few biodegradable plastics. 00:33:01.579 --> 00:33:05.582 Polylactic acid and polybutylene adipate terephthalate, 00:33:05.583 --> 00:33:09.220 both of which are classified in 3907. 00:33:09.854 --> 00:33:13.490 Polylactic acid is a saturated polyester 00:33:13.491 --> 00:33:17.095 that is derived from corn starch or sugarcane. 00:33:17.581 --> 00:33:20.391 Polybutylene adipate terephthalate 00:33:20.398 --> 00:33:24.206 is a polyester copolymer derived from butanediol, 00:33:24.800 --> 00:33:28.272 terephthalic acid, and adipic acid. 00:33:28.673 --> 00:33:33.044 While these products are biodegradable and compostable, 00:33:33.277 --> 00:33:36.780 it should be noted that they are still considered 00:33:36.781 --> 00:33:40.050 plastics for the purposes of Harmonized Tariff 00:33:40.051 --> 00:33:42.452 Schedule of the United States because they meet 00:33:42.453 --> 00:33:50.328 the requirement of Note 1 to Chapter 39 that defines what is a plastic. 00:33:53.131 --> 00:33:56.833 Basically, that note says that throughout the tariff schedule, 00:33:56.834 --> 00:34:02.788 the expression "plastics" means those materials of Headings 3901 to 3914, 00:34:03.307 --> 00:34:08.311 which are or have been capable either at the moment of polymerization 00:34:08.312 --> 00:34:13.527 or at a subsequent stage of being formed under external influence, 00:34:13.551 --> 00:34:18.889 which is usually heat or pressure, sometimes a solvent or plasticizer. 00:34:18.890 --> 00:34:23.360 They can be formed by molding, casting, extruding, rolling, 00:34:23.361 --> 00:34:27.764 or other process into a shape that will be retained 00:34:27.765 --> 00:34:31.369 on the removal of that external influence. 00:34:35.440 --> 00:34:41.855 Heading 3908 covers polyamides and copolymers. 00:34:41.879 --> 00:34:45.249 The linear polyamides are known as nylons. 00:34:45.950 --> 00:34:50.621 They have high tensile strength and resistance to shock. 00:34:50.822 --> 00:34:52.589 They have excellent chemical resistance. 00:34:52.590 --> 00:34:55.826 Some uses for them are textiles, 00:34:55.827 --> 00:35:00.665 molding, coatings, adhesives, packaging films. 00:35:03.428 --> 00:35:07.604 Heading 3909 is amino resins, phenolic resins, 00:35:07.605 --> 00:35:11.074 and polyurethanes in primary form. 00:35:11.075 --> 00:35:15.412 The most notable polymer in this heading is polyurethane. 00:35:15.413 --> 00:35:21.551 It is used in foams, elastomers, and coatings, but we should also note 00:35:21.552 --> 00:35:25.189 that poly(methylene phenyl isocyanate) 00:35:25.423 --> 00:35:30.293 which is also known as crude MDI or polymeric MDI, 00:35:30.294 --> 00:35:33.264 is also classified in 3909. 00:35:36.200 --> 00:35:39.838 I said earlier, I'd say a little bit more about silicones. 00:35:39.839 --> 00:35:43.642 3910 does cover the silicones in primary form. 00:35:43.841 --> 00:35:47.210 Silicones are non-chemically defined products. 00:35:47.211 --> 00:35:50.781 They have more than one silicon-oxygen-silicon 00:35:51.549 --> 00:35:53.650 linkage and contain organic 00:35:53.651 --> 00:35:56.153 groups that are connected to the silicon atoms 00:35:56.154 --> 00:36:00.067 by direct silicon-carbon bonds. 00:36:00.091 --> 00:36:02.659 These silicones have high stability. 00:36:02.660 --> 00:36:05.913 They can be liquid, semi-liquid, or solid. 00:36:07.431 --> 00:36:10.200 They can be the form of silicone oils and greases, 00:36:10.201 --> 00:36:15.449 which are used as lubricants, water repellent, and foam inhibitors. 00:36:15.473 --> 00:36:19.309 They can be in the form of resins, which are used in varnishes, 00:36:19.310 --> 00:36:22.203 insulating, or waterproof coatings. 00:36:23.848 --> 00:36:26.327 They can be used as laminates. 00:36:26.717 --> 00:36:29.653 They can also be silicone elastomers. 00:36:30.034 --> 00:36:34.458 Though silicone is often referred to as rubber, 00:36:34.625 --> 00:36:40.531 it does not meet the definition of synthetic rubber in Chapter 40. 00:36:41.032 --> 00:36:45.969 However, it does have some extensibility that remains 00:36:45.970 --> 00:36:48.615 unchanged by high and low temps. 00:36:49.006 --> 00:36:51.455 It can be used in the manufacture of washer seals, 00:36:51.456 --> 00:36:53.376 heat-resistant products, a lot of things 00:36:53.377 --> 00:36:56.846 that your traditional rubbers are used for, 00:36:56.847 --> 00:37:00.292 but silicone and its products are always classified 00:37:00.293 --> 00:37:04.655 in Chapter 39, the polymers. 00:37:05.122 --> 00:37:06.791 Okay, so 3911, 00:37:09.807 --> 00:37:12.162 the heading covers petroleum resins, 00:37:12.163 --> 00:37:14.213 coumarone-indene resins, polyterpenes, 00:37:14.214 --> 00:37:16.445 polysulfides, polysulfones, 00:37:16.601 --> 00:37:19.903 and other products specified in Note 3 to this chapter, 00:37:19.904 --> 00:37:24.175 not elsewhere provided or included in primary forms. 00:37:24.542 --> 00:37:27.477 Okay, so petroleum resins, coumarone, 00:37:27.478 --> 00:37:29.246 indene, or coumarone-indene resins, 00:37:29.247 --> 00:37:32.515 and polyterpenes are not highly polymerized. 00:37:32.516 --> 00:37:37.387 They are made by polymerizing the less impure fractions 00:37:37.388 --> 00:37:41.925 that have been obtained from deeply cracked petroleum distillates, 00:37:41.926 --> 00:37:46.930 coal tar, turpentine, or other sources of terpenes. 00:37:47.964 --> 00:37:51.968 Polysulfide are polymers that are characterized 00:37:51.969 --> 00:37:55.273 by the presence of monosulfide linkages. 00:37:55.539 --> 00:37:59.030 They are used in coatings and molded articles 00:37:59.577 --> 00:38:03.781 such as aircraft and automobile parts. 00:38:04.397 --> 00:38:09.552 Polysulfones are polymers characterized 00:38:09.553 --> 00:38:14.401 by the presence of sulfone linkages in the polymer chain. 00:38:14.425 --> 00:38:18.868 They're used in electrical parts and domestic appliances. 00:38:22.733 --> 00:38:28.171 Polymers with the isocyanate groups that are not elsewhere 00:38:28.172 --> 00:38:30.774 specified or included are also classified here. 00:38:30.775 --> 00:38:33.810 Some examples are polyureas that are based 00:38:33.811 --> 00:38:37.581 on hexamethylene diisocyanate or HDI. 00:38:37.782 --> 00:38:42.552 Those are used in the manufacture of paints and varnishes. 00:38:42.553 --> 00:38:49.114 Also, the polyisocyanurates based on HDI, 00:38:49.138 --> 00:38:52.862 they're also used in the manufacture of paints and varnishes. 00:38:52.863 --> 00:38:55.031 Then, of course, the other products specified 00:38:55.032 --> 00:38:59.402 in Note 3 to the chapter that are not elsewhere specified or included. 00:38:59.403 --> 00:39:03.073 Some of these examples include polyxylene resins, 00:39:03.074 --> 00:39:06.010 polyvinyl ketones, polyethyleneimines. 00:39:10.348 --> 00:39:14.828 Okay, so we'll stop and catch our breath a minute. 00:39:14.852 --> 00:39:17.331 I hope you're all still awake. 00:39:17.822 --> 00:39:21.710 We'll see if there are a few additional questions. 00:39:21.826 --> 00:39:23.193 >> MODERATOR: Yes, there are some questions that came in. 00:39:23.194 --> 00:39:25.195 We can take a few of them maybe. 00:39:25.196 --> 00:39:28.765 The first one, "Exclusionary note regarding Heading 3208 00:39:28.766 --> 00:39:31.634 was concerned with volatile organic solvents. 00:39:31.635 --> 00:39:34.504 Is there a specific definition of volatile such 00:39:34.505 --> 00:39:37.917 as a specific flashpoint or vapor pressure?" 00:39:41.812 --> 00:39:45.462 >> CHRISTINA: I'm sure I have in my notes probably 00:39:47.852 --> 00:39:48.918 what the flashpoint would be. 00:39:48.919 --> 00:39:52.655 Basically, there is a group of organic compounds 00:39:52.656 --> 00:39:56.306 that are considered volatile organic compounds. 00:40:01.532 --> 00:40:03.199 Basically, those characteristics, 00:40:03.200 --> 00:40:04.634 and I would have to go back and look and see 00:40:04.635 --> 00:40:07.404 what the specific guidelines are for that, 00:40:07.405 --> 00:40:15.779 but you can even actually google that or your search engine of choice, 00:40:15.780 --> 00:40:18.795 that term, and it will give you a list. 00:40:18.816 --> 00:40:20.157 Some of the things that end up 00:40:20.158 --> 00:40:23.954 in there are things like various alcohols. 00:40:25.322 --> 00:40:32.220 I'm trying to think of some types of acids, some formaldehydes. 00:40:33.631 --> 00:40:35.880 Then it depends more so on the concentration 00:40:35.881 --> 00:40:38.773 like it has to be greater than 50%. 00:40:41.205 --> 00:40:43.640 >> MODERATOR: Okay, one more question you got. 00:40:43.641 --> 00:40:47.544 "Is there a limit or CBP criteria to the percentage of additives 00:40:47.545 --> 00:40:51.948 that a polymer can contain to be classified within Chapter 39?" 00:40:51.949 --> 00:40:53.116 And then there's an asterisk, 00:40:53.117 --> 00:40:58.115 "Excluding polymers in solvent solution described in Note 2(e)." 00:40:58.322 --> 00:41:02.860 >> CHRISTINA: There is no specific percentage of additives. 00:41:03.027 --> 00:41:06.563 It is more commonly on what that additive 00:41:06.564 --> 00:41:09.910 does to the function of that product. 00:41:09.934 --> 00:41:12.368 We have had cases before where something 00:41:12.369 --> 00:41:14.504 was predominantly polymer 00:41:14.505 --> 00:41:18.321 and had an additive with a very low percentage. 00:41:18.342 --> 00:41:25.048 However, that additive changed the function of that product. 00:41:25.049 --> 00:41:28.552 It actually, even in that small percentage, 00:41:29.053 --> 00:41:34.143 gave that product a new function that took it 00:41:34.162 --> 00:41:37.098 outside of a polymer in primary form. 00:41:37.962 --> 00:41:40.524 There's no specific percentage. 00:41:40.664 --> 00:41:46.871 I've also had cases where we had wood powder shavings. 00:41:47.137 --> 00:41:49.339 It was in greater percentage than the polymer, 00:41:49.340 --> 00:41:51.574 but the polymer is what formed 00:41:51.575 --> 00:41:56.580 the actual wood plastic composite item. 00:41:56.847 --> 00:42:00.317 Therefore, the wood was just a filler. 00:42:01.051 --> 00:42:04.320 It just depends on the function of that additive, 00:42:04.321 --> 00:42:06.524 not necessarily the percent of that additive. 00:42:07.591 --> 00:42:09.178 >> MODERATOR: Okay. 00:42:09.426 --> 00:42:11.160 Do you want to take one more for now? 00:42:11.161 --> 00:42:12.328 >> CHRISTINA: Yes, I can do one more. 00:42:12.329 --> 00:42:13.658 >> MODERATOR: Okay. 00:42:13.659 --> 00:42:19.202 "3907-61 to 3907-69 reference the viscosity number. 00:42:19.203 --> 00:42:22.855 Previous versions of the tariff used the intrinsic viscosity. 00:42:22.856 --> 00:42:25.275 Does CBP consider these to be interchangeable 00:42:25.276 --> 00:42:30.433 or must the intrinsic viscosity be converted to viscosity number?" 00:42:31.115 --> 00:42:32.682 >> CHRISTINA: That's a little tricky. 00:42:32.683 --> 00:42:37.421 They are very similar, but they are not identical. 00:42:38.422 --> 00:42:43.003 I do not pretend to be a chemist 00:42:43.027 --> 00:42:45.428 and know the formula for the two. 00:42:45.429 --> 00:42:47.664 I know that they have different conversion 00:42:47.665 --> 00:42:50.700 factors in place like as in one is, I think, 00:42:50.701 --> 00:42:54.304 in deciliters versus the other being in milliliters. 00:42:54.305 --> 00:42:58.669 Like I said, they are extremely close but not identical. 00:43:01.145 --> 00:43:02.946 It's one of those cases. 00:43:02.947 --> 00:43:09.153 I think the language of one of the anti-dumping cases 00:43:09.853 --> 00:43:13.590 has the language of a different type of viscosity. 00:43:13.591 --> 00:43:17.003 Maybe that is why we changed here in the US. 00:43:17.728 --> 00:43:19.462 Most of those changes were before me, but no, 00:43:19.463 --> 00:43:22.799 I do not have that conversion factor. 00:43:22.800 --> 00:43:24.868 I think there is one. 00:43:26.036 --> 00:43:27.003 To answer your question, no, 00:43:27.004 --> 00:43:31.174 they are not interchangeable, but they are very similar. 00:43:31.175 --> 00:43:32.442 I would have to actually defer 00:43:32.443 --> 00:43:37.381 to the lab on calculating a conversion from that. 00:43:37.881 --> 00:43:38.748 I would have to go to them 00:43:38.749 --> 00:43:40.783 and then come back to you on that one. 00:43:40.784 --> 00:43:43.015 >> MODERATOR: Okay, thank you. 00:43:48.158 --> 00:43:52.095 >> CHRISTINA: All right, so let's go on and let's finish out 00:43:52.096 --> 00:43:55.032 the final portion of our presentation, 00:43:56.300 --> 00:44:00.037 which would be our natural polymers. 00:44:00.332 --> 00:44:04.007 3912 covers cellulose and its chemical derivatives 00:44:04.008 --> 00:44:08.611 that are not elsewhere specified or included in primary forms. 00:44:08.612 --> 00:44:13.316 Cellulose is a carbohydrate of high molecular weight. 00:44:13.317 --> 00:44:16.619 It forms the solid structure of vegetable matter 00:44:16.620 --> 00:44:21.424 and it is contained in cotton in almost a pure state. 00:44:21.425 --> 00:44:24.927 This covers cellulose, obviously, 00:44:24.928 --> 00:44:28.432 that is not elsewhere specified or included. 00:44:29.033 --> 00:44:34.305 An exclusion that is important to note is regenerated cellulose 00:44:34.775 --> 00:44:37.508 is a glossy transparent material, 00:44:37.944 --> 00:44:42.211 thin, transparent sheets, textile filaments. 00:44:42.212 --> 00:44:45.983 None of those are classified in 3912. 00:44:48.252 --> 00:44:53.652 The sheets are in 3921 and the filaments could be in Chapter 54 or 55. 00:44:56.126 --> 00:44:59.896 This heading also covers the chemical derivatives of cellulose, 00:44:59.897 --> 00:45:02.999 whether or not they have been plasticized. 00:45:03.000 --> 00:45:05.066 Cellulose acetate is one. 00:45:05.335 --> 00:45:08.938 Those are prepared by treating cellulose with acetic 00:45:08.939 --> 00:45:13.303 anhydride and acetic acid in the presence of a catalyst. 00:45:13.777 --> 00:45:18.915 When you add plasticizers, they can form non-flammable plastics 00:45:18.916 --> 00:45:22.062 that are suitable for injection molding. 00:45:22.086 --> 00:45:26.866 They're commonly presented in powdered granules or solutions. 00:45:26.890 --> 00:45:29.792 If the cellulose acetate is in the form of sheet, 00:45:29.793 --> 00:45:33.840 film, rod, tube, they are excluded. 00:45:33.864 --> 00:45:37.831 Because remember, to be classified in 3901 to 3914, 00:45:38.702 --> 00:45:41.972 the products must be in primary forms. 00:45:43.140 --> 00:45:46.076 Cellulose nitrates or nitrocellulose. 00:45:46.710 --> 00:45:49.645 These are prepared by treating cellulose 00:45:49.646 --> 00:45:53.182 with a mixture of nitric and sulfuric acids. 00:45:53.183 --> 00:45:55.414 They're highly inflammable. 00:45:55.686 --> 00:46:00.208 The more highly nitrated varieties are used in explosives. 00:46:00.390 --> 00:46:03.292 These are typically transported dampened with alcohol 00:46:03.293 --> 00:46:07.101 or dampened or plasticized with phthalate esters. 00:46:07.787 --> 00:46:14.071 Celluloids are cellulose nitrate plasticized with camphor in alcohol. 00:46:15.572 --> 00:46:18.174 These usually come in the forms of sheets, 00:46:18.175 --> 00:46:22.856 film, rods, and tubes, and are therefore excluded from 3912. 00:46:29.820 --> 00:46:35.659 >> CHRISTINA: Cellulose acetate butyrate and cellulose propionate. 00:46:36.393 --> 00:46:38.261 They're both cellulose esters. 00:46:38.262 --> 00:46:41.133 They form plastics of the same general character 00:46:41.134 --> 00:46:43.934 as those from cellulose acetate. 00:46:44.902 --> 00:46:47.436 This heading also covers cellulose ethers. 00:46:47.437 --> 00:46:50.949 The most important of which are carboxymethyl cellulose, 00:46:50.950 --> 00:46:54.044 methylcellulose, hydroxyethyl cellulose. 00:46:54.344 --> 00:46:56.327 These are water-soluble. 00:46:56.580 --> 00:46:59.315 They're used as thickeners or glue. 00:46:59.316 --> 00:47:03.362 Ethyl cellulose is used to make lightweight plastic. 00:47:03.687 --> 00:47:07.590 Plastics that are chemically derived from cellulose 00:47:07.591 --> 00:47:11.461 generally do need the addition of plasticizer. 00:47:16.834 --> 00:47:22.605 Heading 3913, the full text of the heading is natural polymers. 00:47:22.606 --> 00:47:25.142 For example, alginic acid. 00:47:25.809 --> 00:47:27.710 Modified natural polymers. 00:47:27.711 --> 00:47:29.545 For example, hardened proteins, 00:47:29.546 --> 00:47:31.981 chemical derivatives of natural rubber, 00:47:31.982 --> 00:47:36.720 not elsewhere specified or included in primary forms. 00:47:36.954 --> 00:47:39.989 Some of the principal natural or modified 00:47:39.990 --> 00:47:43.370 natural polymers of this heading are as follows. 00:47:43.371 --> 00:47:46.264 Alginic acid, its salts and esters. 00:47:46.980 --> 00:47:51.264 Polyuronic acid that's been extracted from brown algae. 00:47:51.935 --> 00:47:58.935 A thing to know is that alginic acid is also insoluble in water. 00:47:59.592 --> 00:48:05.449 Its ammonium and alkali metal salts dissolve readily in cold water. 00:48:06.083 --> 00:48:10.720 It is used as thickeners, stabilizers, gelling, and film-forming agents. 00:48:10.721 --> 00:48:13.089 It's widely used in the pharmaceutical, 00:48:13.090 --> 00:48:15.990 food, textile, and paper industries. 00:48:17.160 --> 00:48:20.053 Our chemical derivatives of rubber. 00:48:20.063 --> 00:48:23.867 Natural rubber itself is a high polymer and, 00:48:24.101 --> 00:48:28.738 when it is chemically treated, can produce or form substances 00:48:28.739 --> 00:48:32.071 that have the characteristic of plasticity. 00:48:32.276 --> 00:48:35.611 These would be things like chlorinated rubber, 00:48:35.612 --> 00:48:39.783 rubber hydrochloride, oxidized rubber, et cetera. 00:48:44.655 --> 00:48:46.934 The Harmonized Tariff Schedule of the United States 00:48:46.935 --> 00:48:50.826 also includes a subheading for polysaccharides and their derivatives. 00:48:50.827 --> 00:48:53.162 This includes the dextran, glycogen, 00:48:53.163 --> 00:48:58.034 which is animal starch, chitin, plastics produced from lignin. 00:48:58.035 --> 00:49:02.637 It also includes isolated amylopectin and isolated amylose. 00:49:04.107 --> 00:49:07.044 It also includes xanthan gum. 00:49:07.377 --> 00:49:09.412 Xanthan gum is a polysaccharide. 00:49:09.413 --> 00:49:11.614 It has useful thickening products. 00:49:11.615 --> 00:49:16.119 It's widely used as a food and cosmetics additive. 00:49:16.620 --> 00:49:20.189 To note is that xanthan gum from China is subject 00:49:20.190 --> 00:49:24.163 to anti-dumping duties under A-570-985. 00:49:25.762 --> 00:49:28.297 One key issue with this case that I just want to bring 00:49:28.298 --> 00:49:30.700 to your attention is that the case does include 00:49:30.701 --> 00:49:36.589 blends that contain at least 15% or more of xanthan gum 00:49:36.590 --> 00:49:40.276 from the People's Republic of China by dry weight. 00:49:40.277 --> 00:49:45.781 It also includes products that are blended and made in other countries, 00:49:45.782 --> 00:49:49.391 which leads me to the fact that there is currently 00:49:49.392 --> 00:49:53.122 a third-country case for xanthan gum from China, 00:49:53.123 --> 00:49:59.690 which has been processed in Canada, and that is case A-122-985. 00:50:04.334 --> 00:50:07.504 Heading 3913, what does it exclude? 00:50:08.638 --> 00:50:11.674 It excludes your unmodified natural resins, 00:50:11.675 --> 00:50:14.711 which are classified in Heading 1301. 00:50:15.278 --> 00:50:21.417 It excludes etherified or esterified flour of locust beans or guar seeds. 00:50:21.418 --> 00:50:23.649 That would be Heading 1302. 00:50:25.625 --> 00:50:29.226 Linoxyn, which is Heading 1518. 00:50:29.793 --> 00:50:32.562 Heparin in Heading 3001. 00:50:33.063 --> 00:50:38.745 Starch ethers and esters, which are Heading 3505. 00:50:38.769 --> 00:50:42.471 Rosin, resin acids, and their derivatives, 00:50:42.472 --> 00:50:48.145 including ester gums and run gums, that's Heading 3806. 00:50:51.515 --> 00:50:56.052 Heading 3914 covers ion exchangers 00:50:56.053 --> 00:50:59.389 based on the polymers of 3901 to 3913. 00:51:00.390 --> 00:51:04.693 The ion exchangers of this heading are cross-linked polymers. 00:51:04.694 --> 00:51:07.596 They're generally in granular form. 00:51:07.597 --> 00:51:10.199 They contain active ionic groups. 00:51:10.200 --> 00:51:12.735 Usually, these groups are sulfonic, 00:51:12.736 --> 00:51:16.440 carboxylic, phenolic, or amino groups. 00:51:17.496 --> 00:51:19.575 Ion exchangers are used in water softening, 00:51:19.576 --> 00:51:21.710 milk softening, chromatography, 00:51:21.711 --> 00:51:24.647 and various other industrial purposes. 00:51:24.915 --> 00:51:27.450 Some of the most common ion exchangers 00:51:27.451 --> 00:51:32.254 are chemically modified styrene-divinylbenzene copolymers, 00:51:32.255 --> 00:51:35.065 acrylic polymers, phenolic resins. 00:51:37.394 --> 00:51:40.830 Note also that this heading does not include 00:51:40.831 --> 00:51:45.591 the ion-exchange columns that are filled with ion exchangers. 00:51:45.802 --> 00:51:51.708 The columns filled with ion exchangers are actually classified in 3926. 00:51:57.714 --> 00:52:00.483 Polymers are extremely complex products 00:52:00.484 --> 00:52:03.345 and they are very difficult to classify. 00:52:03.346 --> 00:52:07.523 As such, this office developed a list of questions 00:52:07.524 --> 00:52:11.293 in conjunction with CBP's laboratory 00:52:11.294 --> 00:52:15.660 and scientific services that would help to aid in our classification. 00:52:16.433 --> 00:52:18.234 For our trade stakeholders on the webinar, 00:52:18.235 --> 00:52:20.936 we suggest that you include this information 00:52:20.937 --> 00:52:24.707 in your binding ruling requests, which would aid in reducing 00:52:24.708 --> 00:52:28.860 the chances that the request is rejected for further information. 00:52:30.881 --> 00:52:34.884 The information here is valuable in the classification of polymers. 00:52:34.885 --> 00:52:37.491 However, it's not all-inclusive 00:52:37.515 --> 00:52:41.924 and not every item will apply to every polymer product. 00:52:41.925 --> 00:52:45.060 The more information supplied with the request helps 00:52:45.061 --> 00:52:48.711 reduce the likelihood that it will be rejected. 00:52:49.566 --> 00:52:52.515 For instance, we need to know the chemical name 00:52:52.516 --> 00:52:55.408 and the CAS number for the product, 00:52:55.603 --> 00:53:01.911 a polymerization flowchart, the chemical formula that indicates 00:53:01.912 --> 00:53:05.314 the average number of repeating monomer units, 00:53:05.315 --> 00:53:07.283 the chemical structure for each component, 00:53:07.284 --> 00:53:11.420 and then the chemical structure for the final product, 00:53:11.421 --> 00:53:14.390 the molecular weight for each monomer unit. 00:53:14.391 --> 00:53:16.692 We like to know the form in which is it imported. 00:53:16.693 --> 00:53:18.995 Is it in liquid? Is it powder? 00:53:20.430 --> 00:53:22.831 The average molecular weight for the final product, 00:53:22.832 --> 00:53:26.335 the percentage by weight of each of the copolymers in the final product. 00:53:26.336 --> 00:53:28.971 This one is very confusing for people. 00:53:28.972 --> 00:53:30.973 If we want to know the percentage by weight 00:53:30.974 --> 00:53:34.210 of each of the copolymers, it's a case of, 00:53:34.211 --> 00:53:38.590 if it was a mixture of a copolymer 00:53:38.591 --> 00:53:41.550 that had polyethylene and polypropylene in it, 00:53:41.551 --> 00:53:47.323 we need to know what percentage of that final copolymer 00:53:47.324 --> 00:53:51.260 is polyethylene and which part is polypropylene, 00:53:51.261 --> 00:53:53.162 which will aid us in determining 00:53:53.163 --> 00:53:56.298 in which heading it should be classified. 00:53:56.299 --> 00:53:58.601 Also, if there is a solvent present, 00:53:58.602 --> 00:54:02.104 we need you to specify the solvent and provide us 00:54:02.105 --> 00:54:04.667 with the weight of its solvent. 00:54:05.542 --> 00:54:08.187 We want to know that percentage. 00:54:11.168 --> 00:54:12.281 On a lot of my requests, 00:54:12.282 --> 00:54:16.329 I will ask you to provide me a complete breakdown. 00:54:16.353 --> 00:54:19.455 Then I want to know every additive that went 00:54:19.456 --> 00:54:22.191 into the product and their percents, 00:54:22.192 --> 00:54:25.995 as well as the function of each of those additives 00:54:25.996 --> 00:54:27.429 within that final product 00:54:27.430 --> 00:54:31.556 because that is also important in the classification. 00:54:32.435 --> 00:54:34.670 Another thing to do is where you think 00:54:34.671 --> 00:54:36.939 your product might be classified if you're doing 00:54:36.940 --> 00:54:40.175 a request will be to go to those headings 00:54:40.176 --> 00:54:43.270 and review the notes for those headings. 00:54:43.546 --> 00:54:46.949 Because like I said in our overviews, 00:54:46.950 --> 00:54:51.420 some of the headings have breakouts for things such as specific gravity, 00:54:51.421 --> 00:54:55.292 relative viscosity, viscosity numbers, et cetera. 00:54:56.626 --> 00:54:58.961 If a heading that you are considering requires 00:54:58.962 --> 00:55:01.397 this specific type of requirement, 00:55:01.398 --> 00:55:06.317 then we would advise providing some type of laboratory analysis 00:55:06.803 --> 00:55:10.974 or other documentation that could provide those parameters to us. 00:55:14.611 --> 00:55:16.879 Another important thing that I get asked 00:55:16.880 --> 00:55:21.384 a lot is about AD/CVD scope rulings. 00:55:22.819 --> 00:55:29.024 Neither headquarters nor the NCSD within CBP issue rulings 00:55:29.025 --> 00:55:33.072 regarding anti-dumping or countervailing duty cases. 00:55:33.096 --> 00:55:38.568 Jurisdiction for AD/CVD lies with the Department of Commerce. 00:55:39.047 --> 00:55:43.172 When importers request whether their goods are subject to AD/CVD, 00:55:43.173 --> 00:55:50.355 CBP can only comment to say that their goods may be subject in a ruling. 00:55:50.847 --> 00:55:56.652 We can't offer you a ruling, but you can request a scope ruling 00:55:56.653 --> 00:55:59.827 directly from the Department of Commerce. 00:56:00.290 --> 00:56:03.025 The ITA's guide on how to file 00:56:03.026 --> 00:56:06.444 for an anti-dumping/countervailing duty scope ruling request 00:56:06.445 --> 00:56:11.601 is available at this link provided here on the slide. 00:56:13.536 --> 00:56:16.405 Yes, you can go and get them a scope ruling 00:56:16.406 --> 00:56:18.140 directly from commerce for that. 00:56:18.141 --> 00:56:23.680 Our office does not issue scope rulings. 00:56:25.081 --> 00:56:27.983 This slide contains our contact information 00:56:27.984 --> 00:56:36.393 as well as the information if you are applying for the CCS/CES credit. 00:56:38.161 --> 00:56:41.061 Now, we'll take the final questions. 00:56:43.199 --> 00:56:45.278 >> MODERATOR: Okay, we have a question. 00:56:45.279 --> 00:56:50.072 "I've seen finished good products produced from EVPM classified 00:56:50.073 --> 00:56:53.275 in Chapter 39 and Chapter 40 in CROSS rulings. 00:56:53.276 --> 00:56:57.164 Where would EVPM in a primary form be classified?" 00:56:57.547 --> 00:57:00.315 >> CHRISTINA: Okay, and as I had asked before, 00:57:00.316 --> 00:57:04.521 I can't classify products just based on name. 00:57:04.921 --> 00:57:08.491 It goes into how they are processed, 00:57:09.561 --> 00:57:11.961 what they are made out of, 00:57:12.195 --> 00:57:16.321 and the different rules for the specific item itself. 00:57:18.701 --> 00:57:20.580 I can't give you a classification 00:57:20.581 --> 00:57:29.813 or say one or the other just from the name of the product, unfortunately. 00:57:30.480 --> 00:57:32.080 It's too complicated for that. 00:57:32.081 --> 00:57:33.480 >> MODERATOR: Sure. 00:57:33.481 --> 00:57:35.938 Another question, "Do you generally find manufacturers' use 00:57:35.939 --> 00:57:37.920 of trade names to be accurate? 00:57:37.921 --> 00:57:41.423 For example, IPR considerations aside, is something invoiced 00:57:41.424 --> 00:57:44.706 as Teflon generally trustworthy as PTFE?" 00:57:49.299 --> 00:57:55.171 >> CHRISTINA: I can't comment on what a company would put on their invoice. 00:57:56.539 --> 00:58:02.022 Teflon is defined as a product made from PTFE, 00:58:02.612 --> 00:58:08.818 but I can't say if what they say on their invoice is PTFE or not. 00:58:09.018 --> 00:58:10.157 >> MODERATOR: Okay. 00:58:10.158 --> 00:58:13.622 "Regarding 3912, what constitutes high molecular weight? 00:58:13.623 --> 00:58:18.027 10,000, 100,000, or 1 million gm per molecule?" 00:58:24.434 --> 00:58:26.668 >> CHRISTINA: I usually deal with the lab on things 00:58:26.669 --> 00:58:33.352 like the high molecular weights, so I'm going to defer that one. 00:58:33.376 --> 00:58:36.011 I'll have to ask them if there is a range. 00:58:36.012 --> 00:58:39.581 I think we do it like with everything else with polymers, et cetera. 00:58:39.582 --> 00:58:41.917 We do case by case. 00:58:41.918 --> 00:58:45.161 >> MODERATOR: Okay. There was a question when you were on slide 23 00:58:45.162 --> 00:58:47.356 and I can read to you what's on that slide. 00:58:47.357 --> 00:58:49.124 There was a question of, "Where did that come from? 00:58:49.125 --> 00:58:50.792 Is that the ENs?" 00:58:50.793 --> 00:58:56.175 That slide contained blocks of irregular shape, lumps, and similar bulk forms. 00:58:56.666 --> 00:58:59.334 You had noted, "may contain fillers, coloring matter, 00:58:59.335 --> 00:59:02.338 or other substances previously cited." 00:59:02.572 --> 00:59:04.308 >> CHRISTINA: Yes, okay. 00:59:05.875 --> 00:59:08.965 Without me looking at actually this 23, 00:59:10.085 --> 00:59:13.204 the notes to Chapter 39, 00:59:13.205 --> 00:59:17.287 and I will try to tell you the specific note, 00:59:19.889 --> 00:59:23.926 the primary forms are defined in Note 6 to Chapter 39. 00:59:23.927 --> 00:59:29.532 That specifically says primary forms applies to these forms. 00:59:29.933 --> 00:59:32.502 Then the further definition of those 00:59:32.503 --> 00:59:34.899 are in the explanatory notes. 00:59:36.873 --> 00:59:38.774 >> MODERATOR: Okay, great. 00:59:40.376 --> 00:59:44.647 Are there UFLPA findings on PET resin from China? 00:59:47.417 --> 00:59:49.400 >> CHRISTINA: I don't know. 00:59:52.088 --> 00:59:55.401 I have not been involved in any as of yet. 00:59:55.425 --> 00:59:57.012 >> MODERATOR: Okay. 00:59:57.762 --> 00:59:59.261 One more question was, 00:59:59.262 --> 01:00:02.431 "There's a material called liquid silicone rubber, LSR. 01:00:02.432 --> 01:00:06.201 Is that 39 or 40 or is that something you cannot address?" 01:00:06.202 --> 01:00:09.938 >> CHRISTINA: I cannot give a specific classification, 01:00:09.939 --> 01:00:12.174 like I said, just based on name without seeing 01:00:12.175 --> 01:00:14.910 the actual composition and things like that. 01:00:14.911 --> 01:00:21.050 In general, a silicone is not classified in Chapter 40. 01:00:24.387 --> 01:00:28.037 I was going to try to see, there's a specific-- 01:00:31.461 --> 01:00:36.932 Note 4 to Chapter 40 explains how something becomes a synthetic rubber. 01:00:36.933 --> 01:00:40.882 To just oversimplify, silicone cannot undergo 01:00:40.883 --> 01:00:44.215 that process and be vulcanized with sulfur. 01:00:44.841 --> 01:00:48.276 In that complicated definition, silicone cannot do that. 01:00:48.277 --> 01:00:53.683 Therefore, silicone is not classified as a rubber. 01:00:53.850 --> 01:00:58.788 Although within industry, it is referred to as a rubber quite often. 01:00:59.489 --> 01:01:02.224 >> MODERATOR: Okay, and then one last question, 01:01:02.225 --> 01:01:06.338 "Do you know how long it usually takes a scope ruling to be issued?" 01:01:06.362 --> 01:01:08.891 >> CHRISTINA: I cannot comment on the timeline 01:01:08.892 --> 01:01:11.801 from the Department of Commerce. 01:01:12.001 --> 01:01:16.365 >> MODERATOR: Okay, that's about all we have for questions. 01:01:18.708 --> 01:01:22.477 >> CHRISTINA: Well, if there are no further questions, 01:01:22.478 --> 01:01:29.478 I will say thank you for attending my presentation today. 01:01:29.919 --> 01:01:34.667 Like I said, our contact information is there on the slides. 01:01:34.691 --> 01:01:38.658 I know that I did cover quite a bit of information. 01:01:40.229 --> 01:01:46.002 Like I said, you're welcome to submit binding rulings. 01:01:47.537 --> 01:01:50.272 You can always email for assistance. 01:01:50.273 --> 01:01:55.077 Many times, though, based on the complexity of these products, 01:01:55.078 --> 01:01:58.613 our office does prefer it in the form of a binding ruling just 01:01:58.614 --> 01:02:02.084 because there are so many factors involved 01:02:02.085 --> 01:02:04.895 in the classification of polymers. 01:02:08.858 --> 01:02:13.963 I will turn it back over to Ms. Harris. 01:02:16.566 --> 01:02:20.402 >> NICOIS: Thank you. This concludes our webinar for this afternoon. 01:02:20.403 --> 01:02:25.006 This is a reminder that this webinar will be posted on the CBP website. 01:02:25.007 --> 01:02:29.371 Thank you for joining us and enjoy the rest of your day.