CLA-2-72:OT:RR:E:NC:1:117

Mr. Thomas J. O’Donnell
8430 W. Bryn Mawr Avenue
Suite 525
Chicago, IL 60631

RE: The tariff classification of various steel products from Germany.

Dear Mr. O’Donnell:

In your letter dated December 30, 2008 you requested a tariff classification ruling.

You are requesting a tariff classification on three types of steel products:

CROVAC 12 is described as cold-rolled strip measuring 2.8 mm in thickness, 275 mm in width and 2000 mm in length. This product is composed of 58% Fe, 28.5% Cr, 12% Co, 1% Mo and <=.02 % C. CROVAC12 is used to manufacture permanent magnets.

VITROPERM 800 is produced by melt spinning wherein molten metal is ejected onto a rotating wheel and the resulting strip is rapidly quenched. Subsequently slit to a width of 46 mm, this strip has a thickness of .018 mm and is imported in coils of successively superimposed layers. Composed of 82.6 % Fe, 9% Si, 5.6 % Nb, 1.5% B, 1.3% Cu and approximately .04 % C, VITROPERM 800 is used to manufacture a variety of articles including pulse current sensitive residual current devices, power transformers, pulse transformers and RFI suppression chokes.

TRAFOPERM is composed of 96.6% Fe, 2.8% Si, .6% Mn and .005-.01 % C. These forged bars, which have a rough circular cross section, are used to manufacture relay parts, measurement systems, needle printers, pole shoes and flux conductors.

The applicable subheading for the CROVAC 12 will be 7220.20.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for flat-rolled products of stainless steel, of a width of less than 600 mm, not further worked than cold-rolled (cold-reduced), of a width of less than 300 mm, of a thickness exceeding 1.25 mm, other, other, other. The rate of duty will be free.

The applicable subheading for the VITROPERM 800 will be 7228.60.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other bars and rods of other alloy steel, angles, shapes and sections, of other alloy steel, hollow drill bars and rods, of alloy or non-alloy steel, other bars and rods, other, not cold-formed. The rate of duty will be free.

You have suggested classification of the TRAFOPERM 800 under subheading 7224.90.00 as other alloy steel ingots or other primary forms, semi-finished products of other alloy steel, other. However, alloy steel forged bars are more specifically provided for in Heading 7228.

The applicable subheading for the TRAFOPERM 800 will be 7228.40.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other bars and rods of other alloy steel, angles, shapes and sections, of other alloy steel, hollow drill bars and rods, of alloy or non-alloy steel, other bars and rods, not further worked than forged. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Mary Ellen Laker at (646) 733-3020.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division