CLA-2-72:S:N:N1:117 889448
Mr. Jonathan M. Fee
Grunfeld, Desiderio, Lebowitz & Silverman
1201 West Peachtree Street, N.E.
Suite 4860
Atlanta, Georgia 30309
RE: The tariff classification of clicker die steel from Austria.
Dear Mr. Fee:
In your letter dated August 13, 1993 on behalf of Viking
Products, Inc., you requested a tariff classification ruling.
The imported product is known as clicker die steel. Clicker
die steel is made by cold-rolling hot-rolled nonalloy strip steel
to the desired thickness. The cold-rolling process includes
"profile rolling". The profile rolling gives the product a non-
rectangular, tapered cross sectional shape and can also form ridges
and grooves which run along the length of the products. Some
typical dimensions (width X thickness) of the clicker die steel are
32 X 4 mm and 19 X 3 mm. After the cold-rolling operation, the
steel is hardened and tempered and the edge or edges are ground to
provide sharpened "cutting bevels". The clicker die steel is
imported in material lengths (cut lengths). After importation it
is cut to the required length and bent to form the desired shape of
cutting die. The cutting dies will be used in a specialty stamping
machine known as a "die cutting press" or "clicker".
The most common types of clicker die steel imported by Viking
are designated by the following product codes: BETR, BD, PZA, BET
and BDQ.
The products designated BD and PZA have cross sections in the shape
of convex polygons and therefore meet the definition for other bars
and rods in Chapter 72 Note 1.(m). The products designated BETR,
BET and BDQ have cross sections in the shape of concave polygons
and therefore meet the definition for angles, shapes and sections
in Chapter 72 Note 1.(n). The clicker die steel contains, by
weight, 0.48 percent of carbon.
The applicable subheading for the clicker die steel having
cross sections in the shape of convex polygons will be 7215.30.00,
Harmonized Tariff Schedule of the United States (HTS), which
provides for other bars and rods of iron or nonalloy steel, other,
not further worked than cold-formed or cold-finished, containing by
weight 0.25 percent or more but less than 0.6 percent of carbon.
The rate of duty will be 7.5 percent ad valorem.
The applicable subheading for the clicker die steel having
cross sections in the shape of concave polygons will be 7216.60.00,
HTS, which provides for angles, shapes and sections of iron or
nonalloy steel, not further worked than cold-formed or cold-
finished. The rate of duty will be 4.9 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport