WEBVTT 00:00:18.350 --> 00:00:19.040 SIKORSKI, KAREN Hello. 00:00:19.040 --> 00:00:23.630 Hello everyone, I'm Nashville import specialist Karen Sikorsky and welcome 00:00:23.630 --> 00:00:25.610 to my webinar today. 00:00:25.610 --> 00:00:30.670 We're gonna cover rubber gloves of heading 4015 and the changes 00:00:30.670 --> 00:00:33.800 for the HTTPS for 2022. 00:00:38.700 --> 00:00:41.330 SIKORSKI, KAREN Here's a copy of our mission statement, 00:00:41.330 --> 00:00:46.390 the one for CBP Customs and Border Protection, and also the one 00:00:46.390 --> 00:00:48.110 for the Office of Trade. 00:00:48.110 --> 00:00:52.220 And I'll give you just a moment to read that if you're not familiar with it. 00:00:56.499 --> 00:01:01.449 SIKORSKI, KAREN I'll read a bit of our disclaimer and that is going 00:01:01.450 --> 00:01:06.830 to tell you that this webinar today is for general info purposes only 00:01:06.830 --> 00:01:12.110 and is intended to provide guidance and information to promote understanding 00:01:12.110 --> 00:01:15.610 and compliance with importing laws and regulations. 00:01:15.610 --> 00:01:15.700 And. 00:01:15.700 --> 00:01:19.820 SIKORSKI, KAREN To be aware of that legislative 00:01:19.820 --> 00:01:23.360 and administrative changes can come up at any time. 00:01:23.360 --> 00:01:28.130 Therefore, we can't take any of the things that we have learned here 00:01:28.130 --> 00:01:32.570 and translate them exactly to a particular situation. 00:01:32.570 --> 00:01:37.890 You'd wanna look to 19 CFR 177, which is the section of the regulation 00:01:37.890 --> 00:01:41.400 that talks about rolling letters that CVP can offer 00:01:41.400 --> 00:01:45.660 to give you a legally binding ruling on a specific transaction. 00:01:45.660 --> 00:01:51.230 SIKORSKI, KAREN And just wanna make you aware that relying solely on me. 00:01:51.230 --> 00:01:52.370 Excuse me? 00:01:52.370 --> 00:01:55.890 Look in general information in this webinar 00:01:55.890 --> 00:01:57.990 may not be considered reasonable care. 00:02:01.989 --> 00:02:05.659 SIKORSKI, KAREN Here's a just another brief disclaimer, and it has to do 00:02:05.660 --> 00:02:10.330 with our audio, visual media and images and sound. 00:02:10.330 --> 00:02:14.570 Just letting you know that it's again provided just for educational purposes 00:02:14.570 --> 00:02:19.750 and doesn't represent any endorsement by customs and also any of the material 00:02:19.750 --> 00:02:24.330 that is gathered here and shown here has been legally obtained 00:02:24.330 --> 00:02:25.860 or is commonly available. 00:02:29.900 --> 00:02:33.000 SIKORSKI, KAREN We bring this up in every webinar, 00:02:33.000 --> 00:02:37.640 but it's just a reminder that we do offer advanced or binding rulings 00:02:37.640 --> 00:02:41.960 on classification, country of origin, free trade agreements 00:02:41.960 --> 00:02:45.560 through our national commodity specialist division. 00:02:45.560 --> 00:02:49.670 If you want to submit an electronic ruling request, there's the link. 00:02:49.670 --> 00:02:54.371 If you happen to forget that particular link, all you have to do is go 00:02:54.372 --> 00:02:59.640 to our website and type in the word electronic ruling or ruling request 00:02:59.640 --> 00:03:01.530 and this will easily come up for you. 00:03:07.633 --> 00:03:10.319 SIKORSKI, KAREN So a brief outline of what we're going to cover today. 00:03:10.320 --> 00:03:12.420 It's going to be a little shorter presentation. 00:03:12.420 --> 00:03:16.670 I hope we're just gonna touch on basic rubber glove classification 00:03:16.670 --> 00:03:18.280 regardless of year. 00:03:18.280 --> 00:03:22.690 The information needed to classify gloves and overview of rubber 00:03:22.690 --> 00:03:28.030 from Chapter 40 of the tariff, the explanatory notes for heading 4015 00:03:28.030 --> 00:03:32.730 and then the changes for gloves and heading 4015 for 2022, 00:03:32.730 --> 00:03:37.150 which we'll touch on medical, surgical dentistry and veterinary gloves, 00:03:37.150 --> 00:03:37.800 how the changes. 00:03:37.800 --> 00:03:39.620 SIKORSKI, KAREN In fact, the past and the present, 00:03:39.627 --> 00:03:41.277 and then I'll take questions at the end. 00:03:43.659 --> 00:03:46.649 SIKORSKI, KAREN So gloves may be classified 00:03:46.650 --> 00:03:50.410 in seven different headings depending on which outer shell material 00:03:50.410 --> 00:03:53.200 of the glove imparts the essential character. 00:03:53.200 --> 00:03:55.920 You have seven choices for any particular glove. 00:03:55.920 --> 00:04:00.860 Plastics gonna go to chapter 39, Robert at chapter 40, leather 00:04:00.860 --> 00:04:06.170 and Chapter 42, first skin and artificial first skin in chapter 43. 00:04:06.170 --> 00:04:09.700 And then when we're looking at textile gloves of Nick construction 00:04:09.700 --> 00:04:12.350 that would be heading 6116. 00:04:12.350 --> 00:04:14.060 Textile gloves of other than net. 00:04:14.061 --> 00:04:18.841 SIKORSKI, KAREN Otherwise known as woven would go to heading 6216. 00:04:20.220 --> 00:04:22.940 SIKORSKI, KAREN So if you have a glove that's composed of two 00:04:22.940 --> 00:04:27.390 or more materials, we'd have to make an essential character determination. 00:04:27.390 --> 00:04:30.357 Normally the palm side from the fingertips 00:04:30.358 --> 00:04:35.010 to the wrist material will determine the essential character. 00:04:35.010 --> 00:04:40.590 I have a couple of different screens going on here, and I've kind 00:04:40.590 --> 00:04:45.520 of lost my notes for a moment, so I may have to toggle back and forth. 00:04:45.520 --> 00:04:49.310 SIKORSKI, KAREN To give you the right reading here, 00:04:49.310 --> 00:04:53.100 but I also did wanna mention that you know we take each glove 00:04:53.100 --> 00:04:58.680 on a case by case basis and when we speak of the palm side material, 00:04:58.680 --> 00:05:02.950 we're generally going to be seeing the outer shell fabric of the palm 00:05:02.950 --> 00:05:05.250 and part in the essential character. 00:05:05.250 --> 00:05:07.630 But that's never 100% of the time. 00:05:07.630 --> 00:05:09.550 There's there's no guarantee on that. 00:05:09.550 --> 00:05:10.950 It just depends on the globe. 00:05:12.950 --> 00:05:15.030 SIKORSKI, KAREN So I have related here. 00:05:15.030 --> 00:05:18.020 The next couple slides some information that I've pulled 00:05:18.020 --> 00:05:24.570 from the regulations that actually are things that are specifically required 00:05:24.570 --> 00:05:26.350 to be able to classify gloves. 00:05:26.350 --> 00:05:28.850 So I'm going to go through some of them for you 00:05:28.850 --> 00:05:32.200 because it will be applicable to rubber gloves and the rest 00:05:32.200 --> 00:05:35.340 of it I'll leave here for your future reference for 00:05:35.340 --> 00:05:37.620 when you're classifying gloves. 00:05:37.620 --> 00:05:42.730 This particular information's gonna be included in our updated gloves. 00:05:42.730 --> 00:05:48.010 SIKORSKI, KAREN Informed compliance publication, which we hope to have all 00:05:48.010 --> 00:05:51.430 of them or many of them released again and reissued this year. 00:05:52.420 --> 00:05:56.840 SIKORSKI, KAREN So for information needed to classify gloves number one, 00:05:56.840 --> 00:06:01.330 we have articles manufactured of textile materials coded or laminated 00:06:01.330 --> 00:06:06.910 with plastics or rubber classifiable and chapters 3940 and 42. 00:06:06.910 --> 00:06:11.160 We must include a description indicating whether the fabric is coated 00:06:11.160 --> 00:06:13.830 or laminated on both sides. 00:06:13.830 --> 00:06:19.050 SIKORSKI, KAREN On the exterior surface or on the interior surface. 00:06:19.050 --> 00:06:24.240 Also for gloves, we need to state if the merchandise has a plastics 00:06:24.240 --> 00:06:28.679 or a rubber exterior and we have a reference here chapter 59. 00:06:28.689 --> 00:06:32.219 Since gloves are made, many gloves are made up of a combination 00:06:32.220 --> 00:06:37.750 of diverse materials such as man-made fiber, woven fabric, plastic overlays, 00:06:37.750 --> 00:06:42.060 artificial fur lining cotton cuffs and the like. 00:06:42.060 --> 00:06:44.310 A detailed breakdown of component materials. 00:06:44.310 --> 00:06:47.430 SIKORSKI, KAREN Is fundamental to classification a full 00:06:47.430 --> 00:06:50.520 and complete description is one that allows the classification 00:06:50.520 --> 00:06:52.390 to be verified easily. 00:06:52.390 --> 00:06:56.629 The invoice, excuse me, must indicate any information 00:06:56.630 --> 00:07:00.130 that has a direct bearing on the classification of the goods. 00:07:02.033 --> 00:07:05.680 SIKORSKI, KAREN This is actually the importer of records responsibility. 00:07:10.033 --> 00:07:12.142 SIKORSKI, KAREN So for proper products of Chapter 40, 00:07:12.143 --> 00:07:17.322 we need a statement as to whether the rubber is combined 00:07:17.323 --> 00:07:20.230 with textile or other material. 00:07:20.230 --> 00:07:24.010 We'd also need a statement as to whether the rubber is cellular 00:07:24.010 --> 00:07:29.340 or non cellular unvulcanized or vulcanized, and if vulcanized, 00:07:29.340 --> 00:07:32.650 whether hard rubber or other than hard rubber. 00:07:34.832 --> 00:07:39.109 SIKORSKI, KAREN And the next couple of slides are information specific 00:07:39.110 --> 00:07:44.010 to gloves that end up getting classified in Chapter 61 and 62. 00:07:44.010 --> 00:07:47.710 So I will just pass through those and you can refer to them 00:07:47.710 --> 00:07:49.200 in the future if you need to. 00:07:49.200 --> 00:07:53.510 If you've got a glove that's got textiles, that may end up in chapter 61 00:07:53.510 --> 00:07:55.490 or chapter 62. 00:07:56.500 --> 00:08:00.340 SIKORSKI, KAREN But I will mention a section F here 00:08:00.340 --> 00:08:05.715 because it talks about for gloves containing textiles and classified in 61 00:08:05.722 --> 00:08:06.419 or 62. 00:08:07.433 --> 00:08:09.550 SIKORSKI, KAREN For gloves, which are constructed 00:08:09.550 --> 00:08:12.700 of more than one component or material which could be 00:08:12.700 --> 00:08:18.260 something like a combination of a net and a woven, or a combination 00:08:18.260 --> 00:08:23.400 of unit and a woven with leather, fur, plastic, et cetera, 00:08:23.400 --> 00:08:27.850 the invoice must show a fiber breakdown in percentages by weight 00:08:27.850 --> 00:08:32.580 for each separate textile material in a material in the glove, 00:08:32.580 --> 00:08:36.970 and a breakdown in percentages by weight for each non textile material 00:08:36.970 --> 00:08:38.200 for the entire glove. 00:08:38.200 --> 00:08:40.910 SIKORSKI, KAREN And this particular section here F kind 00:08:40.910 --> 00:08:44.820 of applies to all gloves because it's basically saying we need 00:08:44.820 --> 00:08:49.090 a percentage weight breakdown for each material in the glove, 00:08:49.090 --> 00:08:51.570 whether it's textile or not. 00:08:51.570 --> 00:08:56.040 SIKORSKI, KAREN Again, I have uh, I pulled all these requirements basically 00:08:56.040 --> 00:09:03.120 from 19 CFR 141.89 which kind of goes through all the invoice requirements 00:09:03.120 --> 00:09:07.010 for special classes of merchandise. 00:09:07.010 --> 00:09:13.030 I will also mention that for gloves when possible, if it's if you're able 00:09:13.030 --> 00:09:15.390 to obtain a sample, do so. 00:09:15.390 --> 00:09:21.640 And the reason why is because sometimes it's hard to envision with only words. 00:09:21.640 --> 00:09:23.340 SIKORSKI, KAREN And when you have a sample a lot 00:09:23.340 --> 00:09:27.370 of times we cut the palm open, sometimes the backside, 00:09:27.370 --> 00:09:30.450 and we can deconstruct them a bit in order to see 00:09:30.450 --> 00:09:32.760 how they are constructed and with what materials. 00:09:42.167 --> 00:09:45.610 SIKORSKI, KAREN So let's lead the USA for just a moment 00:09:45.610 --> 00:09:51.390 and travel to Southeast Asia, where most of the world's rubber is sourced. 00:09:51.390 --> 00:09:55.600 I don't know if you can see my cursor mover, not here. 00:09:55.600 --> 00:09:58.560 I'm not particularly technically talented. 00:09:58.560 --> 00:10:03.020 I haven't learned how to use the pointer yet, but anyway. 00:10:06.300 --> 00:10:08.070 SIKORSKI, KAREN We will. 00:10:10.033 --> 00:10:11.780 SIKORSKI, KAREN Take a look at these beautiful trees. 00:10:11.780 --> 00:10:18.700 Here they are rubber trees and there are over 2500 types of trees 00:10:18.700 --> 00:10:22.690 that produce the SAP used in in natural rubber production. 00:10:22.690 --> 00:10:29.070 But the overwhelming majority of natural latex stems from the rubber tree. 00:10:29.070 --> 00:10:33.530 These trees are native to South America, but are today commonly found 00:10:33.530 --> 00:10:35.130 in Southeast Asia. 00:10:35.130 --> 00:10:40.510 I actually personally visited a defunct rubber factory in Songkhla. 00:10:40.510 --> 00:10:43.480 SIKORSKI, KAREN Highland, which is very far South and close 00:10:43.480 --> 00:10:47.070 to the Malaysian border, believe it or not, I was there to try 00:10:47.070 --> 00:10:51.320 to verify production of knit gloves at that factory. 00:10:51.320 --> 00:10:55.960 As it turned out, the factory had no capability to make anything anymore 00:10:55.960 --> 00:11:00.860 and had all kinds of equipment laying around for rubber production. 00:11:00.860 --> 00:11:04.791 The factory was abandoned and the address was clearly used 00:11:04.792 --> 00:11:06.190 for a false invoice. 00:11:06.190 --> 00:11:07.690 These things do happen. 00:11:07.713 --> 00:11:09.483 Be aware of who you're manufacturer is. 00:11:15.980 --> 00:11:19.579 SIKORSKI, KAREN So natural rubber latex is gathered from the trees 00:11:19.580 --> 00:11:24.270 by making a cut in the bark and collecting the runny SAP and cups. 00:11:24.270 --> 00:11:30.050 This process is called tapping in order to prevent the the SAP from solidifying. 00:11:30.050 --> 00:11:35.160 Ammonias added acid is done added to the mix to extract the rubber 00:11:35.160 --> 00:11:36.990 in a process called coagulation. 00:11:42.500 --> 00:11:45.210 SIKORSKI, KAREN The mixture is then passed through rollers 00:11:45.210 --> 00:11:46.430 to remove excess water. 00:11:54.722 --> 00:11:57.629 SIKORSKI, KAREN Once the excess water is removed, the layers 00:11:57.630 --> 00:12:02.933 of rubber are hung over racks and smokehouses are left to air dry. 00:12:02.940 --> 00:12:06.779 Several days later, they will then be folded into balls ready for processing. 00:12:18.464 --> 00:12:21.030 SIKORSKI, KAREN So going to chapter 40, where we have rubber 00:12:21.030 --> 00:12:24.440 and articles thereof, the first note tells us that except 00:12:24.440 --> 00:12:28.530 where the context otherwise requires throughout the tariff schedule, 00:12:28.530 --> 00:12:31.080 the expression rubber means the following products 00:12:31.080 --> 00:12:34.350 whether or not vulcanized or hard natural rubber, 00:12:34.350 --> 00:12:40.630 which we just saw being made belada, gutta, percha, guayule, 00:12:40.630 --> 00:12:44.930 chuckle and similar i.e. Rubber like natural gums, 00:12:44.930 --> 00:12:49.839 synthetic rubber factus derived from oils and such substances. 00:12:49.840 --> 00:12:51.149 SIKORSKI, KAREN They claimed. 00:12:51.150 --> 00:12:56.300 SIKORSKI, KAREN Robert includes Nitro, which is a synthetic rubber also 00:12:56.300 --> 00:13:01.830 known as NBR, which stands for Nitrol fueding. 00:13:01.830 --> 00:13:07.340 Rubber rubber includes latex, which is generally a liquid form of rubber, 00:13:07.340 --> 00:13:12.580 but could be a plastic, so you might need to ask and latex can be natural 00:13:12.580 --> 00:13:18.070 from the rubber tree or synthetic, which is man made, and I posted a picture 00:13:18.070 --> 00:13:22.280 of the chicklets chewing gum because I was wondering. 00:13:22.280 --> 00:13:26.170 SIKORSKI, KAREN Give chewing gum is still made with chuckle 00:13:26.170 --> 00:13:30.240 and I found out that although natural chuckle is still used, 00:13:30.240 --> 00:13:35.650 most of today's chewing gums are made from synthetic vinyl gum base OO. 00:13:40.482 --> 00:13:41.260 SIKORSKI, KAREN Uh, no. 00:13:41.260 --> 00:13:45.050 Two to Chapter 40 tells us that the chapter does not cover goods 00:13:45.050 --> 00:13:47.080 of section 11, which is textiles. 00:13:47.080 --> 00:13:51.829 It doesn't cover footwear, headwear, mechanical or electrical appliances, 00:13:51.830 --> 00:13:56.990 other chapters, blah blah blah, and down to F it tells us it doesn't cover 00:13:56.990 --> 00:13:59.680 other than chapter 95. 00:13:59.680 --> 00:14:03.570 Other than sports gloves, mittens in which, which means that sports gloves, 00:14:03.570 --> 00:14:08.150 mittens and mitts of rubber can remain in the rubber chapter. 00:14:11.633 --> 00:14:13.990 SIKORSKI, KAREN So, chapter 40, explanatory notes have 00:14:13.990 --> 00:14:17.360 some really good information about rubber and textile combinations, 00:14:17.360 --> 00:14:19.960 which we're not going to get into real deep here because we're kind 00:14:19.960 --> 00:14:24.350 of just talking about the changes to heading 4015. 00:14:24.350 --> 00:14:27.760 But for future reference, I wanted to point this out to you 00:14:27.760 --> 00:14:32.250 because it is extremely helpful should you have a glove that has rubber 00:14:32.250 --> 00:14:33.680 and textile. 00:14:33.680 --> 00:14:37.710 So for rubber and textile combinations, the classification 00:14:37.710 --> 00:14:40.650 and the classification of rubber and textile combos. 00:14:40.650 --> 00:14:43.590 SIKORSKI, KAREN Are essentially governed by. 00:14:43.590 --> 00:14:51.900 Note one IJ to section 11, Note 3 to chapter 56, and note 4 to chapter 59, 00:14:51.900 --> 00:14:55.090 and it basically tells us that the following products are covered 00:14:55.090 --> 00:15:00.610 by this chapter, Chapter 1440, and it breaks out here. 00:15:00.610 --> 00:15:07.180 Felt Nonwovens textile fabrics, plates, sheets, or strips of cellular lover 00:15:07.180 --> 00:15:09.970 of rubber combined with textile fabrics. 00:15:09.970 --> 00:15:13.130 It's basically talking about your requirements about how it. 00:15:13.130 --> 00:15:17.000 SIKORSKI, KAREN If it's going to, you know, remain in Chapter 40, 00:15:17.000 --> 00:15:21.010 it's going to be impregnated, coded, covered or laminate with rubber. 00:15:21.010 --> 00:15:26.050 Having a certain by weight of textile material, or it's completely embedded 00:15:26.050 --> 00:15:29.890 in rubber or in the case of Nonwovens, you're looking 00:15:29.890 --> 00:15:35.250 at a coding being able to be seen with the naked eye 00:15:35.250 --> 00:15:38.490 with textile fabrics we're talking about. 00:15:38.490 --> 00:15:42.880 SIKORSKI, KAREN Umm impregnations coatings coverings or laminations 00:15:42.880 --> 00:15:45.250 with rubbers at a certain weight? 00:15:45.250 --> 00:15:47.150 SIKORSKI, KAREN Et cetera. 00:15:47.150 --> 00:15:50.040 And when we go down to the bottom where we talk about plates, 00:15:50.040 --> 00:15:53.960 sheets or strip of cellular lover rubber combined 00:15:53.960 --> 00:15:58.340 with textile fabrics filter non wovens, it talks about 00:15:58.340 --> 00:16:01.960 where the textiles present merely for reinforcing purposes. 00:16:04.566 --> 00:16:08.569 SIKORSKI, KAREN Some more notes on gloves and coatings chapter 59. 00:16:08.570 --> 00:16:13.660 Note 5 covers rubber and textile combinations and note that for gloves, 00:16:13.660 --> 00:16:18.610 the function of the textile backing must be considered when determining 00:16:18.610 --> 00:16:22.610 if the fabric is serving merely reinforcing purposes. 00:16:22.610 --> 00:16:28.140 Thus, for gloves with the palm or outer shell of cellular rubber, they will not. 00:16:28.140 --> 00:16:32.843 SIKORSKI, KAREN Be made up of a rubberized textile fabric 00:16:32.844 --> 00:16:34.410 of heading 5906. 00:16:34.410 --> 00:16:39.340 If there are combined with the textile fabric where that fabric is present 00:16:39.340 --> 00:16:44.060 for merely reinforcing purposes, meaning it can remain. 00:16:44.060 --> 00:16:48.540 SIKORSKI, KAREN As a rubber glove and heading 4015. 00:16:54.494 --> 00:16:58.019 SIKORSKI, KAREN Here's a glance at the tariff page that we're dealing with 00:16:58.020 --> 00:17:00.170 with heading 4015. 00:17:00.170 --> 00:17:01.850 You see that there's a heading. 00:17:01.850 --> 00:17:06.070 SIKORSKI, KAREN The talks about articles of apparel, clothing, etcetera, 00:17:06.070 --> 00:17:10.300 clothing, articles of apparel and clothing accessories. 00:17:10.300 --> 00:17:13.260 SIKORSKI, KAREN Within the rubber chapter. 00:17:13.260 --> 00:17:17.850 And then there is a specific breakout just for gloves in Chapter 40. 00:17:17.850 --> 00:17:19.640 That's how important these gloves are. 00:17:19.640 --> 00:17:20.792 They have their own little breakout. 00:17:28.767 --> 00:17:32.329 SIKORSKI, KAREN Now the explanatory notes for heading 4015 00:17:32.330 --> 00:17:36.350 for gloves tell us that this heading covers articles of apparel 00:17:36.350 --> 00:17:40.380 and clothing except, well, actually, this explanatory now covers 00:17:40.380 --> 00:17:43.620 not just gloves, but I've kind of put the section here or. 00:17:43.620 --> 00:17:47.670 SIKORSKI, KAREN Brought up the points that really apply to gloves. 00:17:47.670 --> 00:17:51.720 So for heading 4015 when we're talking about gloves, 00:17:51.720 --> 00:17:55.100 we see that this heading includes gloves, mittens and myths, 00:17:55.100 --> 00:17:59.960 protective gloves as well as clothing for surgeons, radiologists, divers, 00:17:59.960 --> 00:18:05.530 et cetera, whether assembled by means of an adhesive or by sewing 00:18:05.530 --> 00:18:06.800 or otherwise obtained. 00:18:06.800 --> 00:18:11.900 So sometimes with rubber textile gloves, you'll have them glued together. 00:18:11.900 --> 00:18:15.010 They could be sewed together, they could be otherwise assembled. 00:18:15.010 --> 00:18:18.790 SIKORSKI, KAREN So these goods may be wholly of rubber, 00:18:18.790 --> 00:18:22.140 which is most of the gloves that we see in chapter 40, 00:18:22.140 --> 00:18:26.370 or they could be of woven, knitted or crocheted fabrics, 00:18:26.370 --> 00:18:31.950 felt or nonwovens impregnated, coated, covered, or laminated with rubber. 00:18:31.950 --> 00:18:34.890 Other than those that fall into Sectional 11, which is 00:18:34.890 --> 00:18:40.290 where we put the textile gloves, the goods can also they may be of rubber 00:18:40.290 --> 00:18:41.860 with parts of textile fabric. 00:18:42.900 --> 00:18:45.780 SIKORSKI, KAREN When the rubber is the constituent giving the goods, 00:18:45.780 --> 00:18:47.920 they're essential character. 00:18:47.920 --> 00:18:50.570 Now the following articles are excluded from this heading, 00:18:50.570 --> 00:18:54.540 and that would be a articles of apparel and clothing accessories 00:18:54.540 --> 00:18:58.020 of textile materials combined with rubber threads that will go 00:18:58.020 --> 00:19:05.310 to chapter 61 or 62 is an apparel item and then also excluded would be footwear 00:19:05.310 --> 00:19:06.400 and headgear et cetera. 00:19:15.432 --> 00:19:18.559 SIKORSKI, KAREN So I'd like to take just two or three minutes 00:19:18.560 --> 00:19:19.950 to do some Ice Breakers. 00:19:19.950 --> 00:19:23.790 We can let that material sink in and you can stretch for a moment 00:19:23.790 --> 00:19:27.080 or grab a drink or just play along with the question so I can get 00:19:27.080 --> 00:19:28.800 to know my audience a bit more. 00:19:28.800 --> 00:19:33.170 SIKORSKI, KAREN You can answer or not in the chat box if you like. 00:19:33.170 --> 00:19:36.244 Just remember this is recorded for future reference, 00:19:36.245 --> 00:19:40.790 so humor is appreciate it, but never at the expense of someone else. 00:19:40.790 --> 00:19:46.559 So I have three questions for you and you can type your answer in the chat 00:19:46.560 --> 00:19:50.870 and I do believe not only I can see it, but everybody else can. 00:19:50.870 --> 00:19:52.930 SIKORSKI, KAREN My first question is. 00:19:52.930 --> 00:19:58.440 SIKORSKI, KAREN Uh, I'm just curious if any of you would be interested 00:19:58.441 --> 00:20:03.249 in classification webinars or type of kind of like seminars 00:20:03.250 --> 00:20:06.040 that would last longer than an hour. 00:20:06.040 --> 00:20:09.120 Is that something you could tolerate? 00:20:09.120 --> 00:20:14.080 Is that something you might be interested in so you can go ahead and? 00:20:14.080 --> 00:20:21.190 SIKORSKI, KAREN Type your answer in the chat if you actually have have one. 00:20:21.190 --> 00:20:23.240 Yes, overwhelming. 00:20:23.240 --> 00:20:26.120 Had open up the chat so I could see what you guys are saying. 00:20:26.120 --> 00:20:28.480 SIKORSKI, KAREN It's OK if you say no. 00:20:28.487 --> 00:20:30.757 I mean I know classification can get really. 00:20:31.990 --> 00:20:35.110 SIKORSKI, KAREN Uh, I can get really boring after a while. 00:20:35.110 --> 00:20:37.010 You have to take breaks. 00:20:37.010 --> 00:20:38.480 Yes, yes, yes. 00:20:38.480 --> 00:20:39.670 Everybody says yes. 00:20:43.500 --> 00:20:44.040 SIKORSKI, KAREN OK. 00:20:48.633 --> 00:20:50.000 SIKORSKI, KAREN Yes, with breaks. 00:20:50.000 --> 00:20:52.230 I couldn't agree more, John. 00:20:52.230 --> 00:20:54.980 OK, alright. 00:20:54.980 --> 00:20:55.490 OK. 00:20:55.490 --> 00:21:01.660 I have another question for you and that is, you know during your work day, 00:21:01.661 --> 00:21:04.901 you're allowed to have a pet wherever you are. 00:21:05.879 --> 00:21:11.749 So you have a choice of a sloth or a parent that talks nonstop. 00:21:11.750 --> 00:21:13.030 Which would you choose? 00:21:15.249 --> 00:21:16.469 SIKORSKI, KAREN Now the sloth. 00:21:16.470 --> 00:21:16.690 I don't know. 00:21:16.690 --> 00:21:20.360 I would kind of personally be inclined, but they might be kind of difficult 00:21:20.360 --> 00:21:21.080 to clean up it. 00:21:23.900 --> 00:21:26.340 SIKORSKI, KAREN What everybody likes the sloth for one. 00:21:26.340 --> 00:21:28.130 SIKORSKI, KAREN I can tell. 00:21:29.766 --> 00:21:33.199 SIKORSKI, KAREN The other non stop talking parrot could really get annoying 00:21:33.200 --> 00:21:34.580 after a while. 00:21:34.580 --> 00:21:37.820 It's kind of hard enough to concentrate sometimes when other people 00:21:37.820 --> 00:21:39.970 are talking the slot go sloth. 00:21:39.970 --> 00:21:43.470 SIKORSKI, KAREN But a pair of would be funny on calls. 00:21:45.237 --> 00:21:47.790 SIKORSKI, KAREN Yes, I love the picture. 00:21:47.790 --> 00:21:48.450 Fong, that's awesome. 00:21:48.450 --> 00:21:52.200 SIKORSKI, KAREN The parrot would be never boring. 00:21:52.200 --> 00:21:52.750 I get it. 00:21:52.750 --> 00:21:56.530 OK, now this is my favorite question, so I hope you play. 00:21:56.530 --> 00:21:59.410 SIKORSKI, KAREN Now you've got a choice. 00:21:59.410 --> 00:22:03.910 Would you rather try a giant semi truck? 00:22:03.910 --> 00:22:09.540 You know, a tractor trailer on the highway or come to work dressed 00:22:09.540 --> 00:22:10.100 as a clown so. 00:22:10.100 --> 00:22:14.520 SIKORSKI, KAREN I think in my case I would. 00:22:14.520 --> 00:22:20.400 I would probably do the clown costume because I don't wanna drive the truck. 00:22:21.433 --> 00:22:24.300 SIKORSKI, KAREN OK, Christy says, truck. 00:22:24.300 --> 00:22:26.760 Ohh, a lot of people driving the truck. 00:22:26.775 --> 00:22:28.305 Lynn would be a clown. 00:22:29.659 --> 00:22:30.689 SIKORSKI, KAREN Umm, clown. 00:22:30.690 --> 00:22:32.700 Ohh, it looks like a toss up. 00:22:32.700 --> 00:22:33.080 Let's see. 00:22:33.080 --> 00:22:33.930 I'm trying to like this. 00:22:33.930 --> 00:22:38.990 This goes along gender lines here or not a tractor trailer typing 00:22:39.005 --> 00:22:40.995 the tractor trailer as a clown. 00:22:42.254 --> 00:22:43.254 SIKORSKI, KAREN Oh gosh. 00:22:44.750 --> 00:22:46.820 SIKORSKI, KAREN Oh gosh, this is too funny. 00:22:46.820 --> 00:22:50.380 Either way, it's OK like driving trucks and people saw people think 00:22:50.380 --> 00:22:51.650 I'm a clown anyway. 00:22:51.650 --> 00:22:53.950 SIKORSKI, KAREN Ohh. 00:22:53.950 --> 00:22:56.850 Diesel shortages in diesel oil shortages coming. 00:22:56.850 --> 00:22:58.690 Gotta point there. 00:22:58.690 --> 00:23:02.620 Mom might be, you know, might be a better might be a safer bet actually. 00:23:03.833 --> 00:23:06.050 SIKORSKI, KAREN Certainly, I don't know what's more dangerous. 00:23:06.050 --> 00:23:07.200 It's hard to say. 00:23:08.167 --> 00:23:09.650 SIKORSKI, KAREN Honestly, I don't know. 00:23:09.650 --> 00:23:11.050 That's good one. 00:23:11.050 --> 00:23:15.120 SIKORSKI, KAREN Ohh you guys are a lot of fun. 00:23:15.120 --> 00:23:16.420 We're gonna have to do this more often. 00:23:17.392 --> 00:23:21.259 SIKORSKI, KAREN OK, so that was only three minutes 00:23:21.260 --> 00:23:23.050 and nobody can fault me for that. 00:23:23.050 --> 00:23:25.390 So a Tesla truck. 00:23:25.390 --> 00:23:26.820 You guys are the best. 00:23:26.820 --> 00:23:28.550 This is good. 00:23:28.550 --> 00:23:29.560 I don't have to pay. 00:23:29.560 --> 00:23:31.370 Play paper filling the tank. 00:23:31.370 --> 00:23:34.130 I would drive the big rig any day. 00:23:34.130 --> 00:23:37.590 OK, now we have to go back to gloves. 00:23:37.590 --> 00:23:42.540 So I hope that we get the opportunity to do this again sometime. 00:23:42.540 --> 00:23:43.500 It was so much fun. 00:23:43.500 --> 00:23:49.760 SIKORSKI, KAREN OK, so back to chapter 40 and our gloves. 00:23:50.700 --> 00:23:53.170 SIKORSKI, KAREN I brought this up for properly 00:23:53.170 --> 00:23:57.268 because we were talking about explanatory notes 00:23:57.269 --> 00:23:59.830 and this is a subheading note 00:23:59.830 --> 00:24:04.640 that used to be part of the explanatory notes back in 2017, 00:24:04.640 --> 00:24:06.890 and you'll see it mentioned in the rulings. 00:24:06.890 --> 00:24:11.180 SIKORSKI, KAREN And what it says is that surgical gloves are thin, 00:24:11.180 --> 00:24:16.350 highly tear resistant gloves manufactured by immersion of a kind worn 00:24:16.350 --> 00:24:17.310 by surgeons. 00:24:17.310 --> 00:24:20.340 They are generally presented in sterile pets. 00:24:20.340 --> 00:24:25.300 Well, this note no longer exists in 2022, yet we can still kind 00:24:25.300 --> 00:24:28.375 of use this information to classify going forward 00:24:28.376 --> 00:24:32.699 as it's simply explains more about what constitutes surgical gloves 00:24:32.700 --> 00:24:34.140 than the current note does. 00:24:34.140 --> 00:24:37.110 And it's not contradictory to the new explanatory notes. 00:24:37.110 --> 00:24:38.310 So we'll accept the past. 00:24:38.310 --> 00:24:41.120 SIKORSKI, KAREN And embrace embrace the future. 00:24:47.299 --> 00:24:52.319 SIKORSKI, KAREN Now for 2022, we have an addition to the explanatory notes 00:24:52.320 --> 00:24:53.810 for heading 4015. 00:24:53.810 --> 00:24:58.830 It's a new subheading note brand new, and this is what it says is it new 00:24:58.830 --> 00:24:59.410 and improved? 00:24:59.410 --> 00:25:01.019 I'm not sure, but it's new. 00:25:01.020 --> 00:25:05.270 SIKORSKI, KAREN Gloves of a kind used for medical surgical, 00:25:05.270 --> 00:25:10.330 dental or veterinary purposes are single use package sterile 00:25:10.330 --> 00:25:16.580 or bulked non sterile gloves with high water tightness and tensile strength 00:25:16.580 --> 00:25:20.570 to protect the patient and the user from cross contamination. 00:25:20.570 --> 00:25:25.470 SIKORSKI, KAREN These gloves may also be used for diagnostic purposes 00:25:25.470 --> 00:25:29.450 in scientific and medical research laboratories, 00:25:29.450 --> 00:25:32.650 or in handling contaminated medical materials. 00:25:34.300 --> 00:25:37.210 SIKORSKI, KAREN While the term diagnostic can have various meetings 00:25:37.210 --> 00:25:39.950 that have nothing to do with health care for the purpose 00:25:39.950 --> 00:25:46.080 of this explanatory note, diagnostic purposes must remain in the context 00:25:46.080 --> 00:25:50.300 of the medical, surgical, dental or veterinary industries, 00:25:50.300 --> 00:25:53.740 because the subheading only covers those industries. 00:25:53.740 --> 00:25:57.280 For example, a mechanic, let's say might use a rubber glove 00:25:57.280 --> 00:26:01.990 to examine a car engine for some reason in order to diagnose specifics 00:26:01.990 --> 00:26:03.890 regarding engine trouble. 00:26:03.890 --> 00:26:06.180 But since his work has no Nexus to medicine. 00:26:06.180 --> 00:26:10.590 SIKORSKI, KAREN Surgery, dentistry or veterinary work? 00:26:10.590 --> 00:26:14.230 They could not be classified under the subheading 00:26:14.230 --> 00:26:15.950 which really brings up a funny story. 00:26:15.950 --> 00:26:18.800 I just thought of my brother in law was a surgeon 00:26:18.800 --> 00:26:22.080 and my other brother in law was. 00:26:22.080 --> 00:26:25.790 I don't know, he he worked in the fire equipment industry and he was, 00:26:25.836 --> 00:26:26.996 you know, very handy guy. 00:26:28.139 --> 00:26:31.599 Well, the surgeon went to go look at a car one time and he put on, 00:26:31.600 --> 00:26:34.520 you know, like Robert gloves to examine the car. 00:26:34.520 --> 00:26:37.730 And my other brother in law laughed hysterically because he's like. 00:26:37.730 --> 00:26:39.530 SIKORSKI, KAREN See what are you wearing those for? 00:26:39.530 --> 00:26:42.960 We're just looking at the car, but apparently my brother-in-law, 00:26:42.960 --> 00:26:46.850 the surgeon had to, you know, work at protecting his hands because, 00:26:46.850 --> 00:26:49.920 you know, it was a surgeon and he didn't want him to get dirty 00:26:49.920 --> 00:26:52.210 or or messed up because they were. 00:26:52.210 --> 00:26:53.370 They were his livelihood. 00:26:55.233 --> 00:26:59.590 SIKORSKI, KAREN Anyway, Umm, this crazy slide here. 00:26:59.590 --> 00:27:07.820 I have to read some notes on this is the 2021 HTS for heading 4015. 00:27:07.820 --> 00:27:12.000 In the past you see we had provisions for surgical and medical, 00:27:12.000 --> 00:27:13.920 both of which were duty free. 00:27:13.920 --> 00:27:20.960 SIKORSKI, KAREN And then other which who the other duty rate can hit 14% 00:27:20.960 --> 00:27:23.670 at the bottom if the gloves are not surgical or medical. 00:27:23.670 --> 00:27:27.480 SIKORSKI, KAREN Previous rulings and explanatory notes have told us 00:27:27.480 --> 00:27:30.770 that surgical gloves are highly terror resistant and sterile. 00:27:30.770 --> 00:27:34.520 Pact and medical gloves are marketed for medical use, 00:27:34.520 --> 00:27:38.180 and the boxes are labeled as examination gloves. 00:27:38.180 --> 00:27:41.780 Well, if you go down to the very bottom of this page for the basket provision 00:27:41.780 --> 00:27:46.790 of 4015 nineteen 50, the only ruling across under this HTTPS was 00:27:46.790 --> 00:27:50.910 for scuba diving gloves which were a combination of rubber and texting. 00:27:50.910 --> 00:27:52.670 I think it might have had some neoprene too 00:27:52.670 --> 00:27:56.130 where the rubber imparted the essential character. 00:27:56.130 --> 00:28:00.280 SIKORSKI, KAREN Word of caution, though, not all diving gloves 00:28:00.280 --> 00:28:01.800 would necessarily go here. 00:28:01.800 --> 00:28:04.740 It depends on the actual construction of the glove. 00:28:04.740 --> 00:28:10.640 Many diving gloves have actually been classified as textiles, and having 6116, 00:28:10.640 --> 00:28:15.760 if you'll recall, the explanatory notes were 4015 mentioned diving, 00:28:15.760 --> 00:28:18.680 but we need to classify on a case by case basis 00:28:18.680 --> 00:28:22.570 and rubber textile combinations require an understanding 00:28:22.570 --> 00:28:26.130 of the actual construction of the glove and the materials and the fabrics. 00:28:26.130 --> 00:28:28.360 SIKORSKI, KAREN Making up that construction. 00:28:33.299 --> 00:28:39.659 SIKORSKI, KAREN The big change for 4015 from 2021 to 2022 is 00:28:39.660 --> 00:28:46.470 that forty 1511.01 that's subheading covering surgical gloves was deleted. 00:28:46.470 --> 00:28:48.020 Forty 1512. 00:28:48.020 --> 00:28:52.060 SIKORSKI, KAREN Was added to add medical surgical, 00:28:52.060 --> 00:28:54.150 dental or veterinary gloves. 00:28:54.150 --> 00:28:59.140 And then 4015 nineteen 05 subheading for medical gloves 00:28:59.140 --> 00:29:01.150 was completely deleted altogether. 00:29:04.300 --> 00:29:05.430 SIKORSKI, KAREN That's it in a nutshell. 00:29:10.033 --> 00:29:10.860 SIKORSKI, KAREN So. 00:29:10.860 --> 00:29:17.850 SIKORSKI, KAREN In 2022, subheading forty 1512 was added 00:29:17.850 --> 00:29:21.450 and really replaced the old 4015 eleven medical 00:29:21.450 --> 00:29:24.680 and surgical gloves remained duty free. 00:29:24.680 --> 00:29:31.100 However, now we have the words Dental and veterinary added to the tariff, 00:29:31.100 --> 00:29:35.740 but now those gloves carry a 14% duty rate. 00:29:35.740 --> 00:29:39.440 We didn't get much of an explanation from the HTTPS tractors 00:29:39.440 --> 00:29:41.100 and what dental or veterinary gloves. 00:29:41.100 --> 00:29:44.050 SIKORSKI, KAREN Actually are, but we'll explore each 00:29:44.050 --> 00:29:47.450 of these gloves a bit based on past CBP rulings 00:29:47.450 --> 00:29:49.090 and the new explanatory notes for the subheading. 00:29:56.833 --> 00:29:58.330 SIKORSKI, KAREN What is a medical glove? 00:29:58.330 --> 00:30:02.890 Well, in general, we've found in the past that medical clubs are marketed 00:30:02.890 --> 00:30:08.420 for medical use and they're dispenser boxes are labeled as examination gloves. 00:30:08.420 --> 00:30:12.910 I think it's typically kind of known as patient examination gloves. 00:30:12.910 --> 00:30:15.100 They're typically disposable as well. 00:30:18.900 --> 00:30:19.730 SIKORSKI, KAREN Umm. 00:30:21.233 --> 00:30:23.150 SIKORSKI, KAREN There are number of headquarters rulings 00:30:23.150 --> 00:30:26.050 that address medical gloves, and you can really dive deep into that 00:30:26.050 --> 00:30:29.060 if you like, but this is the most recent one, 00:30:29.060 --> 00:30:33.290 and it brings home the important points kind of for the from the other rulings. 00:30:33.290 --> 00:30:41.160 SIKORSKI, KAREN And it's HQH 026693 back from 2010 and it tells. 00:30:41.160 --> 00:30:45.740 It tells us that information on medical and non medical gloves can be found 00:30:45.740 --> 00:30:47.160 on the FDA website. 00:30:47.160 --> 00:30:51.370 The FDA has a publication actually entitled guidance for Industry 00:30:51.370 --> 00:30:55.310 and FDA staff, Medical Glove Guidance manual from 2008. 00:30:55.310 --> 00:30:58.880 I have consulted that and I think it is the most recent publication, 00:30:58.880 --> 00:31:02.930 it's got a lot of good information, medical gloves are actually medical. 00:31:02.930 --> 00:31:06.750 SIKORSKI, KAREN Devices that are subject to the federal food, Drug, 00:31:06.750 --> 00:31:13.870 and Cosmetic Act, another ruling headquarters, ninety 65530, was cited 00:31:13.870 --> 00:31:17.120 in the ruling that we're looking at here and it mentioned 00:31:17.120 --> 00:31:21.860 that the expectation of the ultimate purchaser of medical gloves is 00:31:21.860 --> 00:31:26.480 that the gloves serves as an effective barrier between blood borne pathogens 00:31:26.480 --> 00:31:29.740 that may be lethal and the wearer skin. 00:31:29.740 --> 00:31:34.100 Medical use gloves follow channels of trade to clinical settings. 00:31:34.100 --> 00:31:38.130 SIKORSKI, KAREN And the recognition and the trade of medical use is apparent 00:31:38.130 --> 00:31:41.860 by the labeling or medical use and that's, you know, on the box. 00:31:46.033 --> 00:31:49.210 SIKORSKI, KAREN Continuing on with this particular ruling, 00:31:49.210 --> 00:31:53.620 it's noted that heading 4015 is a principal use provision 00:31:53.620 --> 00:31:56.320 and you're probably familiar with the United States 00:31:56.320 --> 00:32:00.630 versus the carborundum company court case, which tells us 00:32:00.630 --> 00:32:02.863 that the following factors can be considered 00:32:02.864 --> 00:32:04.500 in determining the principal use 00:32:04.500 --> 00:32:09.080 of a product and consideration of the pertinent circumstances. 00:32:09.080 --> 00:32:13.700 And just like clockwork, I have noise outside my door. 00:32:13.700 --> 00:32:16.610 Hopefully you can still hear me because there's nothing I can do about it. 00:32:16.610 --> 00:32:17.950 SIKORSKI, KAREN Anyway. 00:32:17.950 --> 00:32:22.310 SIKORSKI, KAREN With medical gloves, we end up sometimes 00:32:22.310 --> 00:32:25.730 and our rubber gloves trying to differentiate between medical use 00:32:25.730 --> 00:32:26.770 and non medical use. 00:32:26.770 --> 00:32:29.110 A lot of times we have to look at these carborundum factors. 00:32:29.110 --> 00:32:32.280 SIKORSKI, KAREN And that would be, you know, we're looking 00:32:32.280 --> 00:32:37.810 at the general physical characteristics, the expectation of the purchasers, 00:32:37.810 --> 00:32:41.620 the class are kind of trade in which the merchandise moves, 00:32:41.620 --> 00:32:46.100 the environment of sale, which would include how the merchandise is marketed, 00:32:46.100 --> 00:32:51.900 the manner in which the merchandise is used, the economic practicality 00:32:51.900 --> 00:32:55.410 and the recognition and the trade of using the imported merchandise 00:32:55.410 --> 00:32:57.830 in a particular manner. 00:32:57.830 --> 00:33:00.110 The headquarters Rollings on this topic. 00:33:00.110 --> 00:33:03.950 SIKORSKI, KAREN Have discussed that some non medical gloves can meet 00:33:03.950 --> 00:33:06.680 the FDA standards for medical gloves. 00:33:06.680 --> 00:33:10.390 However, simply meeting those standards does not mean the gloves 00:33:10.390 --> 00:33:13.080 are medical gloves for classification purposes. 00:33:21.369 --> 00:33:25.140 SIKORSKI, KAREN Here's a rolling on non medical use rubber gloves 00:33:25.140 --> 00:33:29.200 that will give us some clue or some idea of what those are about 00:33:29.200 --> 00:33:33.710 and hecklers rolling to indicate that in the trade standard medical exam gloves 00:33:33.710 --> 00:33:38.050 are often made on the same machines and in the same manner as medical gloves. 00:33:38.050 --> 00:33:41.330 There are differences though in quality and these quality differences 00:33:41.330 --> 00:33:43.420 are governed by the FDA. 00:33:43.420 --> 00:33:47.870 Medical cloves are medical devices as we said that under stringent testing 00:33:47.870 --> 00:33:52.060 of their league resistance they have their leak resistance. 00:33:52.060 --> 00:33:56.710 SIKORSKI, KAREN And adulteration of tested gloves 00:33:56.710 --> 00:34:01.190 that fail the medical glove testing or were not tested may then be sold 00:34:01.190 --> 00:34:05.550 for cosmetic food handling, electronics and other industries 00:34:05.550 --> 00:34:09.170 as industrial use gloves, but not as medical gloves. 00:34:09.170 --> 00:34:11.372 There are strict penalties for attempting 00:34:11.373 --> 00:34:13.050 to insert industrial use gloves 00:34:13.050 --> 00:34:16.850 into the medical use market because they're of different quality. 00:34:16.850 --> 00:34:19.690 SIKORSKI, KAREN The quality difference and the marketing 00:34:19.690 --> 00:34:23.950 of these gloves distinguishes the surgical and medical use gloves 00:34:23.950 --> 00:34:26.530 from the non medical use gloves. 00:34:26.530 --> 00:34:30.730 Labeling is key and dustrial use gloves are labeled as such 00:34:30.730 --> 00:34:33.560 just as medical gloves are typically on the box. 00:34:33.560 --> 00:34:36.110 I'm going to show you some examples of both 00:34:36.110 --> 00:34:40.420 and I have seen circumstances in some import specialists have come to me 00:34:40.420 --> 00:34:44.150 where they have seen kind of like dual labeling like they kind of like. 00:34:44.150 --> 00:34:48.230 SIKORSKI, KAREN Portray that the glove could be used for medical use 00:34:48.230 --> 00:34:53.700 and used for other things, and those who are a little bit more ambiguous, 00:34:53.700 --> 00:34:56.541 but typically you're going to see kind of 00:34:56.542 --> 00:34:59.180 what I'm gonna show you going forward. 00:35:01.099 --> 00:35:04.609 SIKORSKI, KAREN Here's an example of medical use rubber gloves. 00:35:04.610 --> 00:35:06.480 You see, it says right on the box. 00:35:06.480 --> 00:35:08.650 Powder free examination gloves. 00:35:08.650 --> 00:35:13.410 Let's say for the sake of argument, that the side of the box also is marked 00:35:13.410 --> 00:35:18.450 for medical grade and you see the typical nitrile rubber glove. 00:35:18.450 --> 00:35:22.030 SIKORSKI, KAREN Umm that we often see in doctor's offices. 00:35:24.367 --> 00:35:28.250 SIKORSKI, KAREN Now here is an example of. 00:35:28.250 --> 00:35:32.810 SIKORSKI, KAREN A food contact handling gloves 00:35:32.810 --> 00:35:36.350 which we would call nonmedical, use rubber gloves. 00:35:36.350 --> 00:35:39.220 I'm not sure Donuts are really food, but perhaps. 00:35:44.055 --> 00:35:48.509 SIKORSKI, KAREN And this box is a good example 00:35:48.510 --> 00:35:52.750 of a non medical use rubber glove where you can see 00:35:52.750 --> 00:35:56.710 they have specifically labeled this as food service gloves. 00:35:56.710 --> 00:36:00.580 But when you look back at the pictures of the gloves they appear 00:36:00.580 --> 00:36:07.140 to be the gloves themselves appear to be identical, they look identical 00:36:07.140 --> 00:36:10.950 and they may be made the same way, but there are differences in quality. 00:36:10.950 --> 00:36:13.506 SIKORSKI, KAREN Here's some more examples 00:36:13.507 --> 00:36:15.380 of non medical use rubber gloves 00:36:15.380 --> 00:36:18.510 at the top we have rubber gloves being used by a manicurist, 00:36:18.510 --> 00:36:20.170 and the beauty industry. 00:36:20.170 --> 00:36:21.130 The bottom left. 00:36:21.130 --> 00:36:23.230 We have industrial gloves. 00:36:23.230 --> 00:36:27.470 SIKORSKI, KAREN Heavy duty rubber gloves being used to handle chemicals 00:36:27.492 --> 00:36:31.529 and on the bottom right we have typical household rubber dishwashing 00:36:31.530 --> 00:36:33.230 or cleaning gloves. 00:36:35.100 --> 00:36:36.720 SIKORSKI, KAREN What is a surgical glove? 00:36:36.720 --> 00:36:40.420 What we said before, they were highly tear resistant at sterile packed 00:36:40.420 --> 00:36:45.410 and we'll examine some rulings to give us a little bit more information 00:36:45.410 --> 00:36:48.910 on that topic because in the past there was a huge distinction 00:36:48.910 --> 00:36:50.320 between surgical and medical. 00:36:50.320 --> 00:36:52.950 But and there is a difference. 00:36:52.950 --> 00:36:59.050 So this ruling HQ 951489 that from 1992 Tulsa, 00:36:59.050 --> 00:37:03.950 US that the FDA regulations define a surgeons blob as a device made 00:37:03.950 --> 00:37:05.400 of natural or synthetic rubber. 00:37:05.400 --> 00:37:09.330 SIKORSKI, KAREN Intended to be worn by operating room personnel 00:37:09.330 --> 00:37:11.240 to protect a surgical way from contamination. 00:37:11.240 --> 00:37:15.550 SIKORSKI, KAREN FDA guidelines provide the gloves utilized 00:37:15.550 --> 00:37:18.990 during operating procedures meet certain sterility requirements. 00:37:18.990 --> 00:37:24.920 SIKORSKI, KAREN And the appropriate requirements may be not at or subsequent 00:37:24.920 --> 00:37:26.480 to importation. 00:37:26.480 --> 00:37:30.710 If the gloves are identified as medical or surgical gloves. 00:37:31.700 --> 00:37:34.770 SIKORSKI, KAREN Examination gloves are not normally sterile. 00:37:34.770 --> 00:37:39.270 These gloves are packaged into sensor boxes and they're there 00:37:39.270 --> 00:37:42.040 to protect the physician from disease and assured 00:37:42.040 --> 00:37:45.960 that disease will not be transmitted from one patient to another. 00:37:45.960 --> 00:37:50.170 SIKORSKI, KAREN And as a result, they're satisfied those types 00:37:50.170 --> 00:37:55.580 of gloves are satisfactory, satisfactory for medical examination purposes. 00:37:55.580 --> 00:37:59.420 SIKORSKI, KAREN A sterile environment is only a concern 00:37:59.420 --> 00:38:04.290 when there is an open wound where blood may be present, such as during surgery. 00:38:04.290 --> 00:38:08.820 This is just some of the information that was related in this ruling 00:38:08.820 --> 00:38:12.750 on surgical gloves and it's not the only ruling on surgical gloves. 00:38:12.750 --> 00:38:15.890 There's more there should you need to dive deeper. 00:38:15.890 --> 00:38:19.680 SIKORSKI, KAREN This is another example 00:38:19.680 --> 00:38:24.210 of an individually packaged sterile surgical glove. 00:38:25.919 --> 00:38:28.760 SIKORSKI, KAREN Whereas we saw the medical examination gloves 00:38:28.760 --> 00:38:32.670 are the passion patient examination gloves came out of a dispenser. 00:38:32.670 --> 00:38:36.070 But these are individually packaged for surgeons. 00:38:36.070 --> 00:38:40.680 SIKORSKI, KAREN So looking at the next section of 4015, 00:38:40.680 --> 00:38:43.430 we talk about dental gloves, right. 00:38:43.430 --> 00:38:46.170 So what is a dental glove? 00:38:51.142 --> 00:38:52.450 SIKORSKI, KAREN Here we have U.S. 00:38:52.450 --> 00:38:57.690 Navy Lieutenant John Miller from Seal Beach, CA, performing a root canal 00:38:57.690 --> 00:39:02.970 on a fellow servicemen aboard ship in the South China Sea last year. 00:39:05.167 --> 00:39:07.680 SIKORSKI, KAREN Are the gloves that the dentist is using 00:39:07.680 --> 00:39:12.360 for dentistry specialized for dentistry in any way, 00:39:12.360 --> 00:39:15.310 or are they the typical nitrile medical gloves 00:39:15.310 --> 00:39:19.600 that we see medical professionals pull out of dispenser boxes 00:39:19.600 --> 00:39:23.400 for various kinds of examinations or patient care? 00:39:23.400 --> 00:39:29.210 SIKORSKI, KAREN It's hard to say in terms of customs or classification 00:39:29.210 --> 00:39:31.690 because we don't really have any precedence 00:39:31.691 --> 00:39:33.550 in terms of dental club rulings. 00:39:33.550 --> 00:39:37.570 There may be something out there, but I haven't been able to find it. 00:39:38.833 --> 00:39:40.040 SIKORSKI, KAREN UM. 00:39:41.432 --> 00:39:45.599 SIKORSKI, KAREN So before we talk about the elephant, we'll just go back 00:39:45.600 --> 00:39:49.290 and say that I don't know that. 00:39:49.290 --> 00:39:50.730 SIKORSKI, KAREN I don't. 00:39:50.730 --> 00:39:54.790 I haven't seen any rulings for specialized dental gloves, 00:39:54.790 --> 00:39:58.620 but should something come up that is specialized for dentistry, 00:39:58.620 --> 00:40:04.690 certainly we would, you know, classify it under the section for dental clubs. 00:40:04.690 --> 00:40:11.070 But I think typically we do see a lot of dentists offices using kind 00:40:11.070 --> 00:40:14.030 of a standard patient examination glove. 00:40:18.967 --> 00:40:23.020 SIKORSKI, KAREN Here we have elephant veterinary service being performed 00:40:23.020 --> 00:40:27.400 in the Chitwan district in Nepal and it looks like he's wearing 00:40:27.400 --> 00:40:29.360 a typical rubber glove. 00:40:29.360 --> 00:40:30.980 Nothing very specialized. 00:40:37.988 --> 00:40:40.610 SIKORSKI, KAREN And in this case we have. 00:40:40.610 --> 00:40:44.300 SIKORSKI, KAREN A veterinarian, what appears 00:40:44.300 --> 00:40:49.320 to be a veterinarian examining a horse's mouth or his teeth, 00:40:49.320 --> 00:40:53.350 and we don't know if she a veterinarian or is she 00:40:53.350 --> 00:40:55.990 a board certified veterinary dentist? 00:40:55.990 --> 00:40:56.650 Well, thank heaven. 00:40:56.650 --> 00:40:59.830 And we don't really need to know for tariff purposes 00:40:59.831 --> 00:41:03.881 because the veterinary gloves and the dental gloves go in the same place. 00:41:05.339 --> 00:41:09.379 SIKORSKI, KAREN But again, you know, she appears to be wearing some type 00:41:09.380 --> 00:41:13.080 of a rubber glove that looks kind of typical. 00:41:13.080 --> 00:41:19.120 It could be a she's doesn't appear to be performing surgery, but it it could be. 00:41:19.120 --> 00:41:23.400 You know, the typical patient examination glove or medical glove 00:41:23.400 --> 00:41:24.440 that we've already seen. 00:41:29.510 --> 00:41:33.820 SIKORSKI, KAREN So here is the newest HTS for heading 4015. 00:41:33.820 --> 00:41:38.210 Again, medical and surgical gloves are lumped together. 00:41:38.210 --> 00:41:39.910 They're kind of not separated out. 00:41:39.910 --> 00:41:45.870 They remain duty free dental and veterinary gloves have been added 00:41:45.870 --> 00:41:53.090 and are now due to bullet 14% and I put the words Dental and veterinary 00:41:53.090 --> 00:41:56.430 in there just because that's what I have in my notes because if. 00:41:56.430 --> 00:42:00.580 SIKORSKI, KAREN They're not medical or surgical. 00:42:00.580 --> 00:42:02.180 That's what would go there. 00:42:02.180 --> 00:42:06.280 SIKORSKI, KAREN A dental or veterinary because of what subheading? 00:42:06.280 --> 00:42:11.600 Forty 1512 actually tells us O CBP has a body of rulings 00:42:11.600 --> 00:42:14.260 that divine both surgical and medical gloves. 00:42:14.260 --> 00:42:18.630 SIKORSKI, KAREN And that's it. 00:42:18.637 --> 00:42:22.557 We don't have a whole lot for veterinary or dental. 00:42:23.580 --> 00:42:27.610 So I suspect that many veterinarian dental offices 00:42:27.610 --> 00:42:32.240 are using standard medical patient examination gloves in their practices 00:42:32.240 --> 00:42:33.780 for many tasks. 00:42:33.780 --> 00:42:38.760 Then how are we to distinguish medical surgical gloves from dental 00:42:38.760 --> 00:42:41.530 or veterinary gloves when? 00:42:41.530 --> 00:42:43.420 SIKORSKI, KAREN Or or. 00:42:43.420 --> 00:42:45.990 Then if they are essentially the same glove, well, 00:42:45.990 --> 00:42:51.020 I can't fully answer that question today and I can't comment 00:42:51.020 --> 00:42:53.630 that we'd have to look at the carborundum factors in terms 00:42:53.630 --> 00:42:57.600 of how the glove is described as well as how it's designed, 00:42:57.600 --> 00:43:00.100 marketed, sold and principally used. 00:43:00.100 --> 00:43:04.350 And this might go beyond a cursory invoice review of the product 00:43:04.350 --> 00:43:05.360 and the photo here. 00:43:05.360 --> 00:43:10.680 It looks like a standard nitrile rubber glove that we see being used 00:43:10.680 --> 00:43:11.520 in an office. 00:43:11.520 --> 00:43:17.400 SIKORSKI, KAREN But by that in the same manner by a vet 00:43:17.400 --> 00:43:22.020 to examine a mountain lions paw and it just kind 00:43:22.020 --> 00:43:24.840 of looks like a typical Asian examination club. 00:43:33.153 --> 00:43:36.080 SIKORSKI, KAREN Perhaps we might like just a little more protection. 00:43:36.080 --> 00:43:40.490 Should a Mountain Lion wake up during a procedure in the veterinarian's office? 00:43:40.490 --> 00:43:44.181 Here's an example of a specialized veterinarian glove 00:43:44.182 --> 00:43:47.145 that might be classified in Chapter 40 00:43:47.146 --> 00:43:50.810 or having 4015 if it was found to have rubber 00:43:50.810 --> 00:43:52.900 as the essential character. 00:43:52.900 --> 00:43:58.630 I was not able to find much on specialized gloves for dentistry. 00:43:58.630 --> 00:44:02.920 However, as you would expect, there are various types of protective gloves. 00:44:02.920 --> 00:44:07.400 SIKORSKI, KAREN Available for veterinary staff to protect themselves 00:44:07.400 --> 00:44:10.520 from bites and scratches from animals and things like that. 00:44:15.122 --> 00:44:17.860 SIKORSKI, KAREN So how do the changes? 00:44:22.037 --> 00:44:25.420 SIKORSKI, KAREN That we talked about affect the past and the present well, 00:44:25.420 --> 00:44:29.360 there isn't much of a ruling history for dental or veterinary gloves. 00:44:29.360 --> 00:44:33.210 So I would encourage you to submit ruling requests going forward 00:44:33.210 --> 00:44:37.190 if questions arise as per medical and surgical gloves, 00:44:37.190 --> 00:44:39.130 only statistical numbers have changed. 00:44:39.130 --> 00:44:41.010 Really not the duty rate. 00:44:41.010 --> 00:44:44.270 SIKORSKI, KAREN Now under the umbrella of gloves used 00:44:44.270 --> 00:44:48.970 for medical, surgical, dental or veterinary purposes are those 00:44:48.970 --> 00:44:53.600 that not only are gloves with high water tightness and tensile strength 00:44:53.600 --> 00:44:57.120 to protect the patient and the user from cross contamination, 00:44:57.120 --> 00:45:02.020 but also those that may be used for diagnostic purposes. 00:45:02.020 --> 00:45:06.060 SIKORSKI, KAREN In scientific and medical research laboratories 00:45:06.060 --> 00:45:12.820 and in handling oops contaminated medical materials. 00:45:12.820 --> 00:45:15.920 So it's this is just our over on the right hand side. 00:45:15.920 --> 00:45:19.890 This is just a rehash of the new explanatory note 00:45:19.890 --> 00:45:25.080 and I would say that if any of those things at the bottom confound you 00:45:25.080 --> 00:45:29.880 with a glove, you know we talked about how a mechanic using 00:45:29.880 --> 00:45:32.960 a gloved it diagnose engine trouble wouldn't be. 00:45:32.960 --> 00:45:37.230 SIKORSKI, KAREN A rubber glove under this purview of medical surgical, 00:45:37.230 --> 00:45:38.430 dental or veterinary. 00:45:38.430 --> 00:45:41.920 But if there's any questions about some of this other wording 00:45:41.920 --> 00:45:46.120 and glove scientific medical, research labs and medical materials, 00:45:46.120 --> 00:45:47.980 you could always submit a rolling request. 00:45:47.980 --> 00:45:51.710 SIKORSKI, KAREN It's my understanding that it's possible 00:45:51.710 --> 00:45:54.930 that the US government is trying to encourage domestic production 00:45:54.930 --> 00:45:58.180 of our own personal protective equipment, and that may be 00:45:58.180 --> 00:46:02.230 why that there's been some of these tariff changes in this heading. 00:46:02.230 --> 00:46:04.900 SIKORSKI, KAREN Just because they're kind of trying 00:46:04.900 --> 00:46:09.590 to segregate out rubber gloves a bit so they can gather some more information 00:46:09.590 --> 00:46:10.910 on importations. 00:46:10.910 --> 00:46:13.710 So there may be additional changes coming. 00:46:13.710 --> 00:46:18.130 I did get a little wind of that, if it would come to pass, 00:46:18.130 --> 00:46:19.890 it probably wouldn't change things. 00:46:19.890 --> 00:46:23.150 SIKORSKI, KAREN Uh, really. 00:46:23.150 --> 00:46:25.870 Significantly, they might just be more interested in kind 00:46:25.870 --> 00:46:27.110 of some of the materials. 00:46:27.110 --> 00:46:31.010 SIKORSKI, KAREN Uh, a different material, breakdowns, whether it's, 00:46:31.010 --> 00:46:33.340 you know, certain kind of rubber or not. 00:46:33.340 --> 00:46:40.810 So I'm going to conclude the webinar with an opportunity for you 00:46:40.810 --> 00:46:44.040 to take a look at our contact info. 00:46:44.040 --> 00:46:47.270 I am located in Middleburg Heights. 00:46:47.270 --> 00:46:49.750 OH, which is a suburb of Cleveland. 00:46:49.750 --> 00:46:53.320 And my email address is herekaren.sikorski@cbp.dhs.gov. 00:46:53.320 --> 00:46:56.150 If we can't answer a question or. 00:46:56.150 --> 00:47:00.510 SIKORSKI, KAREN Something that you were interested 00:47:00.510 --> 00:47:02.600 in learning more about today. 00:47:02.600 --> 00:47:07.280 You can always email me and we can discuss the email or via phone. 00:47:07.280 --> 00:47:11.210 My associate Lisa Angular is actually located in New York 00:47:11.210 --> 00:47:15.990 at the World Trade Center and her contact info is below as well. 00:47:15.990 --> 00:47:18.850 She does have an M there in the middle of her name. 00:47:18.850 --> 00:47:23.120 SIKORSKI, KAREN And if you would send us an email, it would probably be best 00:47:23.120 --> 00:47:25.050 if you included both of us. 00:47:25.050 --> 00:47:29.440 So I thank you for the applause and I. 00:47:29.440 --> 00:47:36.340 SIKORSKI, KAREN I'm going to mention that you could thank you very much. 00:47:36.340 --> 00:47:39.800 You could type your question in the chat box. 00:47:39.800 --> 00:47:41.740 I will try to open that up again. 00:47:41.740 --> 00:47:49.500 SIKORSKI, KAREN And then also I think my show associates 00:47:49.500 --> 00:47:54.000 could unmute your mic if you would prefer to ask the question instead. 00:47:55.711 --> 00:47:59.750 SIKORSKI, KAREN So I'm going to hang on for a few minutes here 00:47:59.750 --> 00:48:02.680 just in case you do have questions. 00:48:02.680 --> 00:48:05.267 I did run a little longer than I thought. 00:48:05.664 --> 00:48:10.430 SIKORSKI, KAREN Thank you very much for the kind of two claps and a sloth. 00:48:10.430 --> 00:48:11.270 I love that. 00:48:12.833 --> 00:48:16.899 SIKORSKI, KAREN So if anybody. 00:48:16.900 --> 00:48:19.230 SIKORSKI, KAREN Wants to speak ohh. 00:48:19.230 --> 00:48:21.070 You could raise your hand. 00:48:21.070 --> 00:48:22.630 Hopefully I could find that. 00:48:22.630 --> 00:48:25.740 SIKORSKI, KAREN And we can unmute you. 00:48:25.740 --> 00:48:28.067 I think we might have a question. 00:48:29.167 --> 00:48:29.480 SIKORSKI, KAREN Uh. 00:48:29.480 --> 00:48:32.880 KONG, FUNG KING A sunny when and Sandra raised their hand. 00:48:32.880 --> 00:48:33.780 SIKORSKI, KAREN OK. 00:48:33.780 --> 00:48:35.833 KONG, FUNG KING They have my taxes. 00:48:36.257 --> 00:48:37.160 SIKORSKI, KAREN They do. 00:48:37.160 --> 00:48:40.170 OK, so sunny. 00:48:40.170 --> 00:48:41.560 Do you wanna go ahead with your question? 00:48:58.680 --> 00:49:01.240 SIKORSKI, KAREN I don't know if Sunny heard that 00:49:01.240 --> 00:49:02.790 or if I maybe can't hear them. 00:49:06.100 --> 00:49:07.280 KONG, FUNG KING One, Sandra. 00:49:07.280 --> 00:49:11.160 You're welcome to unmute your mic and ask your questions. 00:49:11.160 --> 00:49:14.460 SIKORSKI, KAREN Yeah, maybe she didn't realize she had to. 00:49:15.767 --> 00:49:17.690 Sandra Hensley I I meant to applause, sorry. 00:49:17.698 --> 00:49:19.228 SIKORSKI, KAREN On. 00:49:20.440 --> 00:49:20.894 SIKORSKI, KAREN Ohh. 00:49:22.067 --> 00:49:23.197 SIKORSKI, KAREN Thank you. 00:49:23.198 --> 00:49:24.090 SIKORSKI, KAREN That's fine. 00:49:24.090 --> 00:49:25.500 And Roseanne, thank you for the for the bow. 00:49:25.500 --> 00:49:30.930 SIKORSKI, KAREN Preciate that OK, there seems to be another person 00:49:30.930 --> 00:49:35.240 that has a question initials SH. 00:49:35.240 --> 00:49:38.200 Do you wanna unmute your mic or do you want me to try to do it? 00:49:38.200 --> 00:49:41.267 Or was that you sunny? 00:49:41.267 --> 00:49:43.267 Sandra Hensley That was me, Sandra. 00:49:43.267 --> 00:49:43.830 SIKORSKI, KAREN OK. 00:49:43.830 --> 00:49:45.380 Sandra Hensley Start. 00:49:45.380 --> 00:49:47.280 SIKORSKI, KAREN I can't Fung. 00:49:47.280 --> 00:49:51.180 I can't tell who else might have a question that wants to speak. 00:49:52.300 --> 00:49:55.540 SIKORSKI, KAREN And yes, Patricia, we will send out the presentation. 00:49:59.694 --> 00:50:00.347 SIKORSKI, KAREN Well. 00:50:00.800 --> 00:50:03.860 SIKORSKI, KAREN I think people are dropping off and I think. 00:50:03.860 --> 00:50:05.760 KONG, FUNG KING Uh, you do have a couple of questions. 00:50:05.760 --> 00:50:06.520 SIKORSKI, KAREN I do OK. 00:50:06.520 --> 00:50:08.600 KONG, FUNG KING Yeah. 00:50:08.600 --> 00:50:10.170 From Karen. 00:50:10.170 --> 00:50:11.170 She would love. 00:50:12.180 --> 00:50:15.740 I would love it if you show a few examples of gloves 00:50:15.740 --> 00:50:17.550 in each of the tariff headings. 00:50:19.659 --> 00:50:23.349 KONG, FUNG KING And she also asked where would you classify rubber gloves 00:50:23.350 --> 00:50:23.840 to protect a manic? 00:50:23.840 --> 00:50:24.490 SIKORSKI, KAREN Do you? 00:50:25.633 --> 00:50:27.300 KONG, FUNG KING A manicure while cleaning house. 00:50:32.212 --> 00:50:36.969 SIKORSKI, KAREN OK, so As for pictures of a gloves in each heading, 00:50:36.970 --> 00:50:40.470 there is a presentation that I did some time ago 00:50:40.470 --> 00:50:43.640 called basic glove classification. 00:50:43.640 --> 00:50:48.370 SIKORSKI, KAREN I think it was maybe 2018 that I did that 00:50:48.370 --> 00:50:53.800 and it should be online available for everyone to access 00:50:53.800 --> 00:50:58.980 and I do believe I do have pictures of just about every different heading there 00:50:58.980 --> 00:51:02.638 and I think that my answer your question, 00:51:02.639 --> 00:51:05.600 if not you can certainly email me 00:51:05.600 --> 00:51:08.060 and you know we we can I can help you find it. 00:51:09.099 --> 00:51:12.879 The other I didn't quite hear the second part of the. 00:51:12.880 --> 00:51:17.190 SIKORSKI, KAREN Question and that was something about. 00:51:17.190 --> 00:51:20.820 SIKORSKI, KAREN Uh, manicures, gloves, cleaning the house 00:51:20.820 --> 00:51:21.610 or something like that. 00:51:21.610 --> 00:51:22.510 KONG, FUNG KING Yeah. 00:51:22.510 --> 00:51:27.500 What were you classify rubber gloves to protect a manicure while cleaning house? 00:51:27.500 --> 00:51:33.470 SIKORSKI, KAREN Uh, well, it would depend on the rubber gloves that you. 00:51:33.470 --> 00:51:38.020 So what they would really be, it sounds like is household use, 00:51:38.020 --> 00:51:41.080 rubber gloves and maybe they're dishwashing gloves or general kind 00:51:41.080 --> 00:51:42.460 of cleaning gloves. 00:51:42.460 --> 00:51:47.070 And if they are primarily or determined to be of the essential character 00:51:47.070 --> 00:51:50.550 of rubber, they would go and heading 4015 00:51:50.550 --> 00:51:54.038 and they would go under the classification 00:51:54.039 --> 00:51:57.120 for something other than medical use. 00:51:57.120 --> 00:51:57.810 Right. 00:51:57.810 --> 00:51:58.420 So. 00:51:58.420 --> 00:52:02.560 SIKORSKI, KAREN I'm heading back if you're still on here, to. 00:52:02.560 --> 00:52:05.160 SIKORSKI, KAREN A tariff page. 00:52:05.160 --> 00:52:06.230 Maybe we can take a quick look. 00:52:09.567 --> 00:52:12.720 SIKORSKI, KAREN So you see, for if it's a rubber glove 00:52:12.720 --> 00:52:16.680 and you're in heading 4015, you would go down to the other 00:52:16.680 --> 00:52:20.550 and then you would have to determine if it was seamless or not. 00:52:20.550 --> 00:52:23.140 If it was seamless, which a lot of them are. 00:52:23.140 --> 00:52:27.370 SIKORSKI, KAREN You'd have to decide that's disposable or not. 00:52:27.370 --> 00:52:31.190 SIKORSKI, KAREN And I think a lot of them, you know, 00:52:31.190 --> 00:52:33.160 these kind of clubs are gonna go to the other. 00:52:33.160 --> 00:52:35.800 They're they're not medical surgical or dental. 00:52:35.800 --> 00:52:37.733 So you just kind of go through it 1 by 1. 00:52:37.733 --> 00:52:39.267 SIKORSKI, KAREN Umm. 00:52:46.880 --> 00:52:49.130 SIKORSKI, KAREN OK, I hope that answered your question. 00:52:49.130 --> 00:52:52.590 If it doesn't, like I said you, we can, we can follow up after the fact. 00:52:55.432 --> 00:53:01.424 SIKORSKI, KAREN Somebody asked Patricia, what if you use nitrile gloves 00:53:01.424 --> 00:53:06.033 for medical exams and for scientific laboratories? 00:53:07.900 --> 00:53:09.332 KONG, FUNG KING OK. 00:53:09.333 --> 00:53:12.050 SIKORSKI, KAREN So we talked about how that. 00:53:12.050 --> 00:53:18.310 SIKORSKI, KAREN Uh, explanatory now kind of was new about, you know, 00:53:18.310 --> 00:53:23.310 being able to use these glove and scientific laboratories. 00:53:23.310 --> 00:53:26.380 SIKORSKI, KAREN Ohh you used it for both. 00:53:26.380 --> 00:53:28.660 I think I is what you're saying, Patricia. 00:53:28.660 --> 00:53:32.980 SIKORSKI, KAREN Umm well it would be fine 00:53:32.980 --> 00:53:36.280 because it it doesn't matter because. 00:53:38.700 --> 00:53:40.410 SIKORSKI, KAREN The science gloves used 00:53:40.410 --> 00:53:43.810 in scientific laboratories under that purview or going to go 00:53:43.810 --> 00:53:45.570 in the same place, so. 00:53:46.609 --> 00:53:48.481 SIKORSKI, KAREN It it it could fall under that. 00:53:49.265 --> 00:53:53.398 SIKORSKI, KAREN Classification for 40 fifteen 1210 zero zero 00:53:53.399 --> 00:53:56.169 of a kind used for medical or surgical. 00:53:56.170 --> 00:53:58.590 SIKORSKI, KAREN Purposes. 00:53:58.590 --> 00:54:01.130 Ohh yeah, yeah, I see what you're saying. 00:54:01.130 --> 00:54:06.050 SIKORSKI, KAREN Ohh is it used used for medical exams and for scientific? 00:54:06.050 --> 00:54:07.020 SIKORSKI, KAREN Yeah. 00:54:10.232 --> 00:54:12.790 SIKORSKI, KAREN That's a good one for Tricia, that would be the kind 00:54:12.790 --> 00:54:18.020 of thing we probably have to dig kind of deep into the principal use, 00:54:18.020 --> 00:54:22.700 and we might have to gather more information as to who how it's. 00:54:22.700 --> 00:54:26.840 SIKORSKI, KAREN What channels of trades going to 00:54:26.840 --> 00:54:31.330 and how it's actually being sold and marketed and distributed? 00:54:31.330 --> 00:54:36.550 So yeah, it's it's it's gonna be a bit confusing, 00:54:36.550 --> 00:54:40.440 but that's the kind of thing where you have the specifics 00:54:40.440 --> 00:54:44.780 of that particular import transaction are going to be 00:54:44.780 --> 00:54:46.890 what's gonna determine the answer. 00:54:48.755 --> 00:54:50.360 SIKORSKI, KAREN OK. 00:54:50.360 --> 00:54:53.870 Well, if anybody has any other. 00:54:53.870 --> 00:54:57.420 SIKORSKI, KAREN Questions. 00:54:59.800 --> 00:55:04.230 SIKORSKI, KAREN Then we can follow up via email or phone discussions. 00:55:04.230 --> 00:55:07.574 So I hope you all have a wonderful afternoon 00:55:07.575 --> 00:55:10.100 and it was nice working with you. 00:55:10.100 --> 00:55:11.100 Take care.