Wednesday 25th January 2017

HS Codes latest position

FSA/ ESA has been holding meetings to determine the correct HS codes to be used for the various sealing products. A recommended list (Rev 3 January 2017) has been issued [pdf].

We have agreed that the HS codes used by members were OK for all products except Gaskets.

We focussed on AF sheet as the contentious one.

We had received some good feedback from ESA members. These included Eriks; Donit; Eagle Burgmann; Klinger; and Flexitallic. Colleen Dupuis at Garlock USA had provided the US Customs and Border Protection agency notes on Gaskets, which provided the clear definition of how HS codes are to be created.

We all agreed that the code must use the chapter for the component/ ingredient that gives the sheet its defining characteristics. So in AF sheet, this is the Kaolin, Aramid fibre, Glass and Mineral fibres used as base materials which are relevant to the products characteristic. The Rubber and other Elastomers, though they may be the largest component by weight, are used as a binder. Rubber does not give the final product its main characteristic.

One suggestion was that AF calendered sheet might be defined as:
"Gaskets made from Synthetic Inorganic Materials, Glass, Aramid, and Mineral fibres, charged with fillers and bonded with an elastomer". This would lead to the code 6815 99 00 being the correct one for AF sheet.

If we then focus on sheet made with Graphite and Carbon, the correct code would be 6815 10 00 which is for non-electrical items of Graphite.

We therefore are asking for any feedback or alternative recommendations, prior to issuing our final view of the correct HS codes to use.

David Mitchell, Standard and Legislation Director

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