CLA-2-72:OT:RR:NC:1:117
Ms. Carol Robertson
Carmichael International Service
533 Glendale Boulevard
Los Angeles, California 90026-5097
RE: The tariff classification of a flat-rolled product from China.
Dear Ms. Robertson:
In your letter dated November 16, 2012 you requested a tariff classification ruling on behalf of your client, Accentra, Inc. A representative sample was included with your submission and will be retained by this office.
The product under consideration is described as 210 galvanized, cold-rolled steel flat wire. This “wire” will be imported in coils of successively superimposed layers and further processed into staples. It consists of 210 individual wires having a thickness of .02 inch (0.50 mm) and a width of .03 inch (0.76 mm). You indicate that the “wire” is flattened, reducing the thickness to 0.041 mm and the width to 0.495 mm, lined edge to edge, glued together for support and rolled into a coil. The coil has a width of approximately 103.5 mm.
You suggest classification of the “wire” in subheading 7217.20.5000, Harmonized tariff Schedule of the United States (HTSUS), which provides for wire of iron or nonalloy steel, plated or coated with zinc, flat wire. Steel wire is defined in HTSUS Chapter 72 Note 1(o) as “Cold-formed products in coils, of any uniform solid cross section along their whole length, which do not conform to the definition of flat-rolled products."
Flat-rolled steel products are defined in HTS Chapter 72 Note 1(k) as "Rolled products of solid rectangular (other than square) cross section…in the form of…coils of successively superimposed layers…." Since the “wire” is imported in coils of successively superimposed layers rather than in spirally oscillated wound coils, it meets the definition of a flat-rolled product and therefore would not be classified as wire.
The applicable subheading for the 210 galvanized, cold-rolled steel flat wire will be 7212.30.3000, HTSUS, which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated, otherwise plated or coated with zinc, of a width of less than 300 mm, 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 Mary Ellen Laker at (646) 733-3020.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division