CLA-2-84:OT:RR:NC:1:104
Mr. Patrick McCooey
Mitsubishi International Corp.
655 Third Avenue
New York, NY 10017
RE: The tariff classification of a 160 Inch Plate Mill Heat Treatment Leveler and Spare Leveling and Back Up Rolls from South Korea and Japan
Dear Mr. McCooey:
In your letter dated July 12, 2011 you requested a tariff classification ruling.
The 160 inch Plate Mill Heat Treatment Leveler is being imported as replacement steel manufacturing equipment for use in a steel plate rolling mill. These plates will be used for high strength commercial applications such as machinery, mining and construction industries. The leveler is used in the process of shaping steel slab into the desired thickness, width, length and hardness. Weighing approximately 1,500 tons, the Leveler is imported disassembled in one shipment. While the electrical and hydraulic systems will be separately provided in the United States, the mechanical components, as entered, do possess the essential character of a complete or finished leveler.
Included with the shipment are spare Leveling Roll Assemblies and Back Up Roll Assemblies. According to supplemental information you submitted on August 1, 2011, the Leveling or Back Up Roll Assemblies consist of the specific roll(s) plus sundry items which together form one unit (i.e., an assembly.) Roll assemblies are installed as one unit. There are two types of Leveling Roll Assemblies. Type-A has two rolls and Type-B has one roll. Both types of leveling assemblies consist of the leveling roll(s), chocks, two bearings (roller bearing and spherical roller bearing) and assorted hardware (spacers, nuts and end plates). There are two types of Back Up Roll Assemblies. Type-A has two rolls and Type-B has one roll. Type-A and Type-B Back Up Roll Assemblies consist of back up roll(s), a spherical roller bearing, roll support, cap and piping. Rolls are made of forged alloy steel. With the exception of one Back-Up roll and the bearings which are manufactured in Japan, the merchandise is manufactured in South Korea.
In your letter, you propose classifying the spare rolls in subheading 8455.30.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Metal-rolling mills and rolls therefore; parts thereof: Rolls for rolling mills. However, as noted above, the rolls are imported as assemblies which are comprised of several components, rolls being one of the components. As the rolls are not being imported separately, subheading 8455.30.00, HTSUS, would not be appropriate.
The applicable subheading for the 160 Inch Plate Mill Heat Treatment Leveler, imported as described above in one shipment, will be 8455.21.0000, HTSUS, which provides for Metal-rolling mills and rolls therefore; parts thereof: Other rolling mills: Hot or combination hot and cold. The rate of duty will be Free.
The applicable subheading for the spare Leveling and Back Up Roll Assemblies will be 8455.90.8000, HTSUS, which provides for Metal-rolling mills and rolls therefore; parts thereof: Other parts: Other. 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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division