CLA-2-84:RR:NC:1:104 D89834

Mr. Kent Sunakoda
James J. Boyle & Co.
2525 Corporate Place, #100
Monterey Park, CA 91754

RE: The tariff classification of rolling mill guides from Japan.

Dear Mr. Sunakoda:

In your letter dated March 12, 1999 on behalf of Sanyo Special Steel U.S.A., Inc. you requested a tariff classification ruling.

You state that the guides are installed before and after the rolls within the steel rolling mill line. Their function is to guide steel billets in and out of the rolls to ensure accurate shaping and sizing of the final product. The brochure from the manufacturer Kotobuki Sangyo Co., Ltd. includes guides for slitters and measuring devices in addition to guides for rolling mills. In a followup fax of April 8, 1999 you indicate that the models at issue here are only for rolling mills. The guides do not have a motor. The guides are installed on the rest bar at the entry side and the delivery side of the mill stand.

There are three types. The literature indicates that the DF type is for use in non-twist rolling of roughing, intermediate and finishing stands. The unit has an interchangeable friction guide fixed to its guide box with a cotter. It is used on the delivery side and has no rollers. The next two types are used on the entry side and have rollers. The EPDR type is said to be especially effective for holding stock to be rolled as two pairs of guide rollers hold the stock firmly at four points. Two holder plates with a symmetrical pin mechanism allow for the simultaneous fine adjustment of the guide roller gap. The ERN type has been developed for use on roughing mill stands. This guide features a nosepiece to guide the stock to the vertical center line of the rolls.

The applicable subheading for the DF, EPDR and ERN guides will be 8455.90.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts for metal rolling mills: other. The rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Robert Losche at 212-637-7038.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division