>> CHRISSI GUTH: Good afternoon. I
am Chrissi Guth with CBP's Office of Trade
Relations. This webinar is part of the
NCSD 2023 webinar series. Please be
mindful you will be on mute during the
presentation and we is ask that you use
the chat feet your feature. If you need
credits, please check the chat box
through the completion code.
I would like to pass it over it
import specialist. Kathy Souffront.
.
>> KATHY SOUFFRONT: Cat thank you,
Chrissi. Good afternoon, , welcome to
the webinar. Reinforced/laminated
headgear. And I use 358 headgear and
apparel for clothing.
In case we come across technical
difficulties, after the webinar I will
provide my information it so you can
e-mail me questions directly.
This is our mission. CBP mission
statement, protect the American people,
safeguard our borders and enhance the
nation's economic prosperity.
The Office of Tray Mission
Statement. The Office of Trade
facilitates legit trade, enforces US laws
and gives a level playing field.
Disclaimer. (Reading). Because
many factors in issues, we have have a a
ruling on the Customs & Border
Protections missions customs matters.
We rely solely on the information
provided here and now consider it
reasonable care.
Here's another disclaimer. States
that the images in the webinar is public
domain and only metropolitan for the
context provided.
In case you missed something, this
webinar, as well as other webinars
presented by other NI S's have been
recorded or will be available on our
website.
Here we have the CBP's binding
ruling program, enabling importers and
binding classification, and areas are
classification, county of origin,
marking and trade program or agreement.
And keep in mind, it will be for
prospective shipmentsle only and you can
find the link on the bottom.
If you can't fill out the form
electron likely, this link will taking
you to the requirements of the linking
program.
It is important to stay current with
the harmonized tariff schedule, , as
they are constantly rolling additions
and agreements and as well as changing
rights. The link will taking to the
current version of the tearive.
That is an example of the harmonized
system schedule, including 6506, we'll
discuss today. On the international, we
have the chapter, , heading and
subheading. And this year it will be
Chapter 6 5, so the heading will be 50 6
providing other headgear whether lined
or trimmed and subheading for 6506.10
for safety headgear.
Moving to county specific. We have
6506.10.30, of reinforced or laminated
plastics and similar to what we'll be
discussing later on.
From physical classification, we
have 6506.10.45, proing for athletic,
recreational or sporting headgear.
There's a total of six GRIs for
determination we can see the
classification on this slide.
We have notes, notes, and more notes
shall and we have general notes, section
notes, chapter notes, subheading notes,
additional U.S. notes, and statistical
notes. These are the classifications
when arriving at classification
decisions.
And explanatory notes are the -- the
classification of goods and nonbinding
and usually indicative of the
hormoneized schedule. The link at the
bottom. Here we have the areas of
responsibility in NIS 548. I handle the
Chapter 6 5, headgear and participants,
and change's apairal, and worn clothing
heading 6309.
Okay. Let's get started. So mid
last year, the field started receiving
several protests and receiving from HDS
6506.10.60.45 here. And it is the
athletic recreational sporting head
gear, in the including plastics.
And to 6506.10.30.45 here, and
includes all of the headgear, all
reinforced or segregated plastics.
And some of those enforced with
collusions for section 301 for these
specific numbers.
We ran a query in one of our systems
to get the transfer for previous years
to compare them and be able to
understand what the issues with a for
the tariff numbers. On the graph we see
the blue line here, and it is for
6506.30.45, forehead he had plastics,
and compared to the orange line, so it
is made above the orange line.
Let orange line is for 6506.60.45
for nonreinforced plastic.
Take a look at years 2020 and 2021.
There's a spike right here on the
orange line. It is equivalent to
approximately 68 percent increase in
value, and these are when the conclusions
came out.
In 2022, there's another noticeable
increase, the blue line we see here, and
it is for athletic gear, reason coursed
or laminated plastics and the collusion
of north one remain in effect.
Take a look at the quoesh yes, it
is. Here we have 6506.10.30.45,
collusion of laminated plastics for about
a year. Meaning the importers didn't
have to pay duties at all since this is
duty free to begin with, however, the
exclusion is now expired.
In other words, headgear coming from
China 6 50 6.30.35, and collusion of
9903.88 .15, and 75%.
And here we have 6506.10.60.45,
provided safety headgear, and not
reinforced headgear plastics.
Here, it is until 9/30/2023,
allowing to bring in gear without
reinforced plastics without subject to
duty on section 301.
To find out if headgear is
reinforced or laminated plastics is to
send it to the CBP lab.
What are helmets composed of? There
are three distinct parts: The shell,
the liner, and the strap.
And there are three kinds of
materials widely used for the out are
shells on most helmets. We are ABS,
acrylonitrile beauty Dean desire even.
PVC --
ABS is most used for bicycle
helmets, ski helmets skateboard and
safety helmets. And PVC is light weight,
heat and usually made for poly
carbonate, ECS -- PVC is a more
transparent material, but a little light
than other materials. And light weight,
heat insulation, heat preservation and
flame retardant and light construction.
The other one is PC has excellent in
impact, also excellent in impact
resistance, weather resistance, weather
retardant and however, this made with
poly cash gnat shells and more expensive
than other materials.
And poly edge reason, material in
plastic bottles. More expensive than
other ones and newer materials in
development for most helmets. For
example, military helmets have UHMPME,
more effective for preventing bullets
from passing the old materials. And
eventually, some of the science may be
adapted to sporting helmets as well.
We have the liner now, the liner
being the most important part of the
helmet. Is the foam usually poly sty
reason or EPS, and some of the foam used
in the bicycle helmet, and expanded EPP,
and standed poly you're thaen, EPU, and
each type has different manufacturing to
ink. And the straps mostly made of
nylon or poly propylene. And the
difference in fabric, finish and weave
and original smaller characteristics.
What is headgear reinforced or
laminated plastics. This frame is not
defined in the tariff, and if not
defined we're looking at explanatory
notes as well as dictionary definitions.
We'll look at dictionary definitions
first.
The Webster as military dictionary,
defined laminated plasticcing and
support, stronger support. The American
Heritage Dictionary to find a strain and
-- material.
Oxford English dictionary,
reinforced plastic, as plastic
strengthened by the inclusion of a layer
of fiber.
And Webster's third new
international dictionary, defined
laminated plastic as a plastic made of
supervisor posed layers of paper, word,
or fabric bonded or impregnated with the
resin and compressed under heat.
The key is the reinforcing material
straightens the plastic.
Now, look at the explanatory notes
to heading 6506. It says this heeding
covers all hats not classified in this
chapter or Chapter 6 3, 68 or 95, and
coverage letic head gear, military or
firearm's helmets motorcycleists miners
construction workers helmets whether or
not fitted with protective padding or in
the case of certain hell et cetera. .
Heading also covered hats with headgear
of rubber, Lieger or composition
leather, fur skin or artificial fur.
Mothers or artificial lowers metal.
And this doesn't explain the xib --
however, used to reinforce plates,
sheets, and plastics. So the ENs also
mentioned the plates, sheets of plastics
in chapter 39 may incorporate a
reinforcement, or supporting mesh or
other material. Like wire, glass,
fibers, et cetera, and needs to be
embedded in the body of the plastics.
I will take a look at other terms,
lamb nation. The bonding of one or more
layers of preexisting materials.
Note 3 to Chapter 5 9, for the
purposes of heading 5903, laminated with
plastics means products made by the
assembly of one or more layers of
fabrics or one or more sheets of film or
plastics, when combined film and
plastics together, and whether or not
the sheets or film of plastics are
visible to the naked eye in the cross
section. And the process of lamb
nation, the process of adhesive of one
to another, and pressed with heat. In
other words, the front side and backside
are both made of material.
And those enforced are the ones in
primary material and second to material
making it more durable, turf,
stronger. Think of Congress create steal
wire or remember ar.
And think of plastics. If the
textile takes metal or other material
making it reinforced. The key is the
reinforce the material straightens the
plastic.
Here we have the headquarters
ruling, asking 65 owe 06.60.30, and not
reinforced plastics.
Used with molding and -- Chapter 9
for plastics and Chapter 7 0 for
glass. Chapter 39 is certain
combinations of plastics and materials
other than textiles, provided they
maintain the character of articles or
plastics.
Also, products consisting of fiber
and heat adhesion consisting of
character.
The character, if paper or articles
of glass fibers. They are classified in
Chapter 8 8 or 70s at the case maybe.
Chapter 7 0, explanatory notes
include combining plastic fibers with
rigid plastics. If having lost the
character of less fibers article.
And composed of layers of woven
fiber glass material, intone Nate and
bound together with plastic. Especially
PS chapter 39 plastics and Chapter 7 0
class.
And determined the article and
plastic, and basic manufacturing, and
author to lost or laminated plastics,
therefore the laminated helmet classified
in 6506.10.30.30.
Okay. So these are examples sent to
the lab or analysis. On the sample, the
plastic shell almost completely
surrounded the EPS foam, and almost
covering the edged.
I have questions for you. And do
you think the phone reinforces the
plastic? This is a question we get. If
you know the answer, you can type in the
chat box yes or no.
I see a lot of nos. I have only see
two yes -- three, four, okay. Yes,
yes. No. Okay.
So you ready for the answer? No.
The foam doesn't reinforce the plastic.
The key is the reinforced material
reinforces the plastic and therefore has
to be embedded in the plastic.
Okay. On this picture, we have a
bicycle helmet. The plastic shell
bonded on a small amount of glue. We see
the glue here.
The glue was not formerly applied
and does not cover the surface. Could
we say that is a laminated helmet? You
can type the answer in the chat box.
Okay. No. No. Okay. Well,
exactly, the answer is no. Remember,
lamb nation is the bonding one or more
layers of preexisting materials and
compressed under here. And here the
bonding only happens in certain spots,
so the answer is no. It is not
considered laminated.
Okay. On this last picture, the
outer shell completely surrounds the EPS
foam, and you see this picture in the
middle of the there's also fabric
coverings at the edges.
The outer shell contains fiber
glass. Could we say that helmet is
reinforced plastic? Good. Yes. Yes. I
see a lot of yes. Anyone -- anyone
thinks otherwise? It is not considered
reinforced?
Okay. The answer is yes. It is
considered reinforced. A helmet
considered reinforced plastic because of
the fiberglass which is embedded in the
plastic in the shell.
Remember, it can be either off,
reinforced or of laminated plastics.
If you have a helmet online
laminated, but not reinforced plastics,
you can still enter it under 6506.10.30
and reinforced plastics. And vice versa
if you have a helmet not reinforced, it
can still be head put in this heading.
And I hope you have learned a lot in
this presentation and whether or not the
helmet is reinforce the plastic
laminated head gear. These are links
you may find helpful.
And this is my contact info, and the
associate I work with. Ivory Wong. And
special thanks to Amy Wong -- and all
handling the webinars to ensure think
run smoothly. Thank you, ladies and I
hope you all enjoyed it and if you have
any questions, just let me know. Thank
you.
>> CHRISSI GUTH: Katherine, someone
asked you to put the links back up.
>> KATHY SOUFFRONT: Sure. Here
they are.
>> CHRISSI GUTH: This concludes our
webinar this afternoon. If you have
logged into the webinar with your
e-mail, you will receive an e-mail from
CCS/CVS within 24, and it will be posted
on the CVA website. Thank you for
joining us and have a great rest of your
day.
[End 10:58 a.m. PST]