CLA-2-82:OT:RR:NC:1:104
Ms. Karla Johnson
Hayes Lemmerz International Inc.
15300 Centennial Drive
Northville, MI 48167
RE: The tariff classification of Stamping Dies from Spain
Dear Ms. Johnson:
In your letter dated February 3, 2010 you requested a tariff classification ruling.
The stamping dies are used in a metal stamping press to produce parts of wheels for passenger cars. Sheets of metal are placed in the stamping press and then the dies are pressed into and through the metal to form the center part of the wheel. A review of the submitted mechanical drawings shows the dies in question to be progressive die units which consist of a series of dies in a holder.
Each die in the series performs an independent metal-working operation. The drawings identify each die by a separate tool number so as to distinguish the metal-working operation the die performs such as drawing, forming, trimming, flanging, and piercing. The progressive die is a composite good wherein any cutting operations are subordinate to the forming operations. The forming dies create the desired shape and establish the identity of the manufactured part. Thus, the forming dies impart the essential character to the progressive die unit.
In your email dated March 3, 2010, you indicated that the submitted photographs and mechanical drawings need not be returned to your office.
The applicable subheading for the Stamping Dies will be 8207.30.6032, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Interchangeable tools for hand tools, whether or not power operated, or for machine-tools (for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or screwdriving), including dies for drawing or extruding metal, and rock drilling or earth boring tools; base metal parts thereof : Tools for pressing, stamping or punching, and parts thereof: Not suitable for cutting metal, and parts thereof…Stamping dies not suitable for cutting metal. The rate of duty will be 2.9% ad valorem.
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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division