CLA-2-72:RR:NC:1:117 I83738
Ms. Trina Wood
John S. James Co.
P.O. Box 23885
Chattanooga, TN 37422-3855
RE: The tariff classification of clad steel from China.
Dear Ms. Wood:
In your letter dated June 18, 2002 on behalf of C.A.S. Iberia, Inc., you requested a tariff classification ruling. A representative sample of the product to be imported was submitted with your request.
The product to be imported is known generically as “Damascus Steel” and is a clad product consisting of fused layers of two different grades carbon steel (Grades 1095 and 1030). Although this product may also be made of fused layers of carbon steel and alloy steel or carbon steel and nickel, you only request a ruling on the product consisting of two different grades of carbon steel. To produce Damascus steel, the two components or substrates are fused together by heating and hammer welding, typically using a manually controlled trip hammer. The composite material is then reheated, manually folded and re-hammered producing a layered product. The process is repeated until the requisite number of layers is produced in the material. Careful control of folding techniques and manual working of the steel surfaces at appropriate points in the manufacturing process may be used to produce random or specific patterns in the layering, and polishing and surface etching of the finished product will reveal such patterns. This product will be imported in the form of flat bars ground to specific dimensions and will range from 0.100 inch to 0.165 inch in thickness, from 1.25 inches to 5 inches in width and from 4 ½ inches to 15 inches in length. This material will ultimately be used in the production of sporting knife blades.
Flat-rolled products of steel are defined in HTS Chapter 72 Note 1. (k) as “Rolled products of solid rectangular (other than square) cross section…in the form of…straight lengths, which if of a thickness less than 4.75 mm are of a width measuring at least 10 times the thickness….” Steel bars are defined in HTS Chapter 72 Note 1. (m) as “Products which do not conform to any of the
definitions at…(k)…which have a uniform solid cross section along their whole length in the shape of…rectangles (including squares)….” If the subject steel substrates are rolled products and meet the dimensional requirements of Chapter 72 Note 1. (k), they will be classified as flat-rolled products. If the steel substrates are forged products or if they are rolled products but do not meet the dimensional requirements of Chapter 72 Note 1. (k), they will be classified as bar products.
The applicable subheading for the clad carbon steel flat bars meeting the definition for flat-rolled steel will be 7212.60.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated, clad. The rate of duty will be 1.3 percent ad valorem.
The applicable subheading for the clad carbon steel flat bars meeting the definition for steel bars will be 7215.90.5000, HTS, which provides for other bars and rods of iron or nonalloy steel, other, other. The rate of duty will be 1.5 percent ad valorem.
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 Paula Ilardi at 646-733-3020.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division