&&The "781 Aluminum Cleaner and Stainless Cleaner" is a ready-to-use, water based acid cleaner used to clean and remove grease, oil, dirt and white, chalky aluminum oxides before welding. It is also used to remove weld residue and discoloration after welding. This liquid is green/yellow in appearance and consists of phosphoric acid and ammonium biflouride. This product is packaged for retail sale in a one-quart plastic bottle.

&&In your application for an advance ruling, you suggested tariff classification number 3810.10.00.00. This tariff classification number is incorrect.&&&&Heading 38.10 provides for, inter alia, pickling preparations for metal surfaces. The Explanatory Notes to Heading 38.10 state, "[pickling preparations for metal surfaces] are preparations used to remove oxides, scale, rust or tarnish from the surface of metals, or for roughening these surfaces to facilitate certain operations." The Notes further state that the heading does not include cleaning preparations for metals (heading 34.02).&&&&Heading 34.02 provides for, inter alia, cleaning preparations, whether or not containing soap. In order to meet the terms of Heading 34.02, a cleaning preparation must: be a preparation; be other than a good of Heading 34.01; not be a "separate chemically defined compound, or natural product not mixed or prepared"; and be a product that falls within Explanatory Notes I or II (A), (B), or (C). The manufacture's Safety Data Sheet, indicates that this product is intended to be used for the "cleaning and removal of grease, oil, dirt and white, chalky aluminum oxides before welding." It also states that it "removes weld residue and discoloration after welding." The good at issue is a non-soap based preparation that is used for cleaning, which does not fall under Heading 34.01; as such, it meets the terms of Heading&&34.02 and is classified therein.