Classification of PVA sheets in roll form as flexible plastic sheets under tariff item 3920 99 12 was accepted.

100% polyvinyl alcohol sheets in roll form were treated as synthetic plastic articles, and classification was examined under Heading 3920 with the Chapter Notes, General Rules for Interpretation and Explanatory Notes. Although polyvinyl alcohol in primary form falls under the polymer heading, once processed into plain, flexible, non-cellular, non-reinforced, non-laminated sheets not combined with other material, it was no longer regarded as primary form. On that basis, the product's composition, physical form and commercial identity were found to fit tariff item 3920 99 12 as flexible sheets of polyvinyl alcohol, and the requested classification was accepted.

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Issues: Whether 100% Poly Vinyl Alcohol (PVA) sheets in roll form are classifiable under tariff item 3920 99 12 as flexible sheets of polyvinyl alcohol.

Analysis: The product was described as plain, flexible, non-cellular, non-reinforced, non-laminated and not combined with any other material, and was held to be a synthetic plastic article derived from polyvinyl acetate. The classification was examined with reference to the terms of Heading 3920, the relevant Chapter Notes, the General Rules for Interpretation and the Explanatory Notes. The ruling accepted that although polyvinyl alcohol in primary form is covered under the polymer heading, once processed into sheets in roll form it is no longer in primary form and is appropriately classified as a flexible plastic sheet. The product's composition, physical form and commercial identity were held to fit subheading 3920 99 12.

Conclusion: The goods were held classifiable under tariff item 3920 99 12, and the requested classification was accepted.

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