Re: Foil, Foil Wrappers or Foil Scrap CCSB Contact: Shannon C. Allard Telephone (703) 838-1809 allard@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class 71700 FOIL OR FOIL WRAPPERS: see Note, item 71702 71702 NOTE Also applies on wrappers, cut or not cut to individual sizes, for completely covering the sides of metal cans or fiberboard cans, bottles or tubes. 71705 Aluminum or tin: 71710 With paper back, rolled, less than 50 feet (600 inches) per roll, in boxes 125 71715 NOI: 71720 Without paper back or backed with paper weighing 30 pounds or less, see Notes, items 71722 and 71724, in boxes or in Package 2299... 70 71722 NOTE Foil backed with paper weighing 20 pounds or more per ream may also be shipped in rolls completely wrapped with three thicknesses of heavy Kraft paper, the ends of the rolls to be protected by fiberboard not less than 0.100 of an inch in thickness or by 200-pound-test doublewall corrugated fiberboard. 71724 NOTE Weights of paper are per ream of 480 sheets, 24 x 36 inches. 71740 Backed with paper weighing more than 30 pounds, see Notes, items 71724 and 71742, paperboard or pulpboard, in boxes, or in Package 2299... 70 71742 NOTE Foil backed with paper weighing more than 30 pounds per ream may also be shipped in rolls completely wrapped with three thicknesses of heavy Kraft paper, the ends of the rolls to be protected by fiberboard not less than 0.100 of an inch in thickness or by 200-pound-test doublewall corrugated fiberboard. 71760 Lead, lead and tin combined, or zinc with or without paper, paperboard or pulpboard back, in boxes... 70 71800 Foil Scrap, aluminum, lead, lead and tin combined, tin or zinc, with or without paper, paperboard or pulpboard back: Sub 1 In bags... 85 Sub 2 In bales or bundles machine pressed, or in boxes, crates or drums... 60 2015 National Motor Freight Traffic Association, Inc. Subject 4, Page 1 of 6
Proposed Classification Provisions Item Description Class NEW Foil, Foil Wrappers or Foil Scrap, aluminum, lead, tin or zinc, NOI, with or without paper, paperboard or pulpboard backing, in boxes, crates or Package 2299, subject to Item 170 and having a density in pounds per cubic foot of: Sub 1 Less than 15... 92.5 Sub 2 15 but less than 30... 70 Sub 3 30 or greater... 55 71700 FOIL OR FOIL WRAPPERS, etc.... Cancel; see 71702 NOTE Cancel; no further application. 71705 Aluminum or tin:... Cancel; see 71710 With paper back, rolled, etc... Cancel; see 71715 NOI:... Cancel; see 71720 Without paper back or backed with paper weighing 30 pounds or less, etc... Cancel; see 71722 NOTE Cancel; no further application. 71724 NOTE Cancel; no further application. 71740 Backed with paper weighing more than 30 pounds, etc... Cancel; see 71742 NOTE Cancel; no further application. 71760 Lead, lead and tin combined, or zinc with or without paper, etc... Cancel; see 71800 Foil Scrap, aluminum, lead, lead and tin combined, tin or zinc, etc... Cancel; see Analysis Research Project 1220 This proposal is based on information developed through Research Project 1220, which was initiated in March of 2014 in light of evidence of potential interpretation disputes and to investigate the transportation characteristics of foil, foil wrappers or foil scrap. During the course of Research Project 1220, questionnaires were mailed to 124 potential manufacturers or shippers of the involved commodities, along with four trade associations believed to represent those companies. Mailings were sent in April of 2014, and for nonrespondents, a second, follow-up questionnaire was sent in June of 2014, inviting them to participate in the research. Additional questionnaires were sent as the CCSB was made aware of other potential industry contacts. From those mailings, six companies responded that they do not manufacture or ship the involved articles, and six companies provided some Subject 4, Page 2 of 6 2015 National Motor Freight Traffic Association, Inc.
information. Two of the trade associations responded that they do not represent manufacturers or shippers of the involved articles. No responses were received from the remaining associations. History of Provisions The basic provisions of item 71710 were established as a result of action taken on Docket 98, Subject 63 (March 1961). That proposal was approved as modified, and the provisions first appeared in Supplement 5 to NMFC A-6, effective May 18, 1962. The remaining provisions for foil, foil wrappers or foil scrap as currently named in items 71720, 71740, 71760 and 71800 were adopted from the rails in 1936. Since the time of their establishment/adoption, there have been amendments to the involved provisions, including class adjustments, packaging changes and the addition of clarifying or packaging Notes. About Foil, Foil Wrappers or Foil Scrap The involved research encompasses a variety of foil, which is extremely versatile and can be utilized in a myriad of applications (e.g. decorative wrap, pharmaceutical packaging, foodservice, etc.). The involved foil may or may not have a paper backing and can be composed from aluminum, lead, tin or zinc. Some examples of the products involved in the research are shown in the photos below. Transportation Characteristics Density The information of record includes 2,644 density observations submitted by shippers and carriers, observed firsthand on CCSB dock surveys and obtained from the CCSB s Density Study 1. The products range in density from 1.39 to 143.46 pcf, with an average of 23.48 pcf. The frequency distribution for foil, foil wrappers or foil scrap is shown on the following page. 1 The Density Study is part of an ongoing effort by the CCSB to collect information on actual shipments; it is not tied to any particular research project, nor does it target any particular product category. Carriers that choose to participate in the study periodically submit shipment data captured through their respective freight auditing programs. The data is identified by NMFC item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used. 2015 National Motor Freight Traffic Association, Inc. Subject 4, Page 3 of 6
Frequency Distribution % of Figures in Interval 40.00% 30.00% 20.00% 10.00% 0.00% 0.00% 0.08% 0.15% 11.23% 5.11% 5.56% 1.78% 2.19% 30.64% 20.80% 22.47% Density Intervals When the data is evaluated on the basis of the three proposed density groupings, the following ranges and averages are calculated. Density Group Density Range Average Density Percentage of Figures in Group Less than 15 1.39 14.99 10.84 26.10% 15 but less than 30 15.00 29.99 21.97 51.44% 30 or greater 30.00 143.46 41.63 22.47% Handling and Stowability The involved commodities are generally tendered in boxes secured on lift truck skids or pallets, or in crates, which permit mechanical handling and generally provide a flat load-bearing surface. Handling and stowability should be comparable to that of other like-packaged freight. Liability Foil, foil wrappers or foil scrap is not perishable, unusually susceptible to theft, hazardous in nature, unusually liable to damage, nor does it appear likely to damage other freight. Responding shippers reported minimal to no claims for the involved articles. One carrier reported zero claims for the involved products. A second carrier reported that they had one claim for the involved commodities in the last couple of years. The value per pound for foil, foil wrappers or foil scrap ranges from $0.41 to $35.00, with an average of $5.91 per pound. Subject 4, Page 4 of 6 2015 National Motor Freight Traffic Association, Inc.
Relationship to CCSB Policies and Guidelines CCSB policy calls for classification provisions to be as clear as possible to help preclude interpretation disputes. The items named in the Present Classification Provisions herein apply on various types of foil, foil wrappers or foil scrap, which may result in interpretation questions. Therefore, it would be in keeping with CCSB policies to cancel the present provisions with reference to a new item, which would name Foil, Foil Wrappers or Foil Scrap, aluminum, lead, tin or zinc, NOI, with or without paper, paperboard or pulpboard backing. Notes, items 71702, 71722, 71724 and 71742 would be canceled with no further application. CCSB policies also call for establishing or amending classification provisions to reflect a commodity s known transportation characteristics. Information of record for foil, foil wrappers or foil scrap shows that these products have a density range from 1.39 to 143.46 pcf, with an average of 23.48 pcf, and no unusual or significant handling, stowability or liability characteristics. Under CCSB guidelines, an average density of 23.48 pcf is generally associated with class 65, which calls for a minimum average density of 22.5 pcf. However, when commodities exhibit a wide range of densities, which are not accurately represented by a single class, CCSB policies state that density-based provisions may be established. When the data of record is evaluated based on the proposed density breaks at 15 and 30 pcf, the following average densities and classes emerge. Density Group Average Density CCSB Minimum Average Density Guideline Class Based on CCSB Density Guidelines Less than 15 10.84 10.5 92.5 15 but less than 30 21.97 15 70 30 or greater 41.63 35 55 It would be in keeping with CCSB policy and precedent to establish classes predicated on two density breaks 2 at 15 and 30 pcf for the involved products. CCSB packaging policies state that the CCSB is to establish and maintain packaging rules and specifications as necessary to ensure that freight is adequately protected so as to withstand the normal rigors of the LTL environment. Requiring foil, foil wrappers or foil scrap to be tendered in boxes, crates or Package 2299 3 would be in keeping with these policies. Precedent for this approach can be found in Docket 2015-2, Subject 2 (June 2015), involving newspaper inserts or supplements, or magazines or periodicals as named in item 161700. Density was determined to be the primary transportation characteristic since there were no significant negative handling, stowability or liability characteristics. Two density breaks at 22.5 and 30 pcf were proposed to provide a more accurate representation of the identified range in density. That proposal was approved as modified, and the provisions first appeared in Supplement 2 to NMF 100-AO, effective August 22, 2015. 2 The density provisions would include reference to Item (Rule) 170, the inadvertence clause. 3 Package 2299 provides specifications for foil or foil wrappers to be bundled and palletized, and is currently authorized in items 71720 and 71740. 2015 National Motor Freight Traffic Association, Inc. Subject 4, Page 5 of 6
Based on the information of record, this proposal, as docketed, is in keeping with CCSB policies and precedent. Subject 4, Page 6 of 6 2015 National Motor Freight Traffic Association, Inc.