CLA-2-72:OT:RR:NC:N1:117
TARIFF NO: 7219.21.0020, 7220.11.0000, 7225.40.3050, 7226.91.5000, 7225.40.1180, 7226.91.1560
Mr. Daniel R. Doyen
Assistant Manager
Okaya (USA) Inc.
64 W. Seegers Rd.
Arlington Heights, IL 60005-3917
RE: The tariff classification of steel plate from Japan
Dear Mr. Doyen:
In your letter dated April 26, 2016, you requested a tariff classification ruling.
The products you intend to import are described as steel plate which has been hot rolled directly into flat plate and is not in coil form at any time during the processing. The plates are further described as being produced to random lengths with the intent that your customers will further process them to the desired lengths. According to your submission, the plates must be cut or worked in the U.S. before final sale in order to be used. The dimensions of the plate is stated to be between 28mm and 135mm in thickness; between 410mm and 610mm in width; and, between 2 meters and 3.6 meters in length.
Chemistries submitted for various grades show all grades to be alloyed steel. You suggested classification in subheadings 7225.40.1180, 7226.91.1560, and. 7226.91.2560 of the Harmonized Tariff Schedule of the United States (HTSUS), for all grades depending on sizes. We do not agree. These are all classifications for steel plate made specifically of tool steel. Some of the grades do not qualify to be classified as tool steel as defined in Additional U.S. Note 1(e), Chapter 72, HTSUS. One grade listed as S-Star grade satisfies the definition of stainless steel in Note 1(e), Chapter 72, HTSUS. Grades NAK 55, NAK 80 and PXS satisfy only the definition of other alloy steel in Note 1(f), Chapter 72, HTSUS. The remaining grades, DH2F, DHA World, DH31EX, DH21, DC53, DCMX and DHA Thermo satisfy the chemical requirements for tool steel as defined in the HTSUS and noted above.
The applicable subheading for the stainless steel plate of a width of 600 mm or more will be 7219.21.0020, HTSUS, which provides for flat-rolled products of stainless steel, of a width of 600 mm or more: not further worked than hot-rolled, not in coils: of a thickness exceeding 10 mm, other: of a width not exceeding 1575 mm. The general rate of duty will be free.
The applicable subheading for the stainless steel plate of a width of less than 600 mm will be 7220.11.0000, HTSUS, which provides for flat-rolled products of stainless steel, of a width of less than 600 mm: not further worked than hot-rolled: of a thickness of 4.75 mm or more. The general rate of duty will be free.
The applicable subheading for the other alloy steel plate of a width of 600 mm or more will be 7225.40.3050, HTSUS, which provides for flat-rolled products of other alloy steel, of a width of 600 mm or more: other, not further worked than hot-rolled, not in coils: of a thickness of 4.75 mm or more: other, other. The general rate of duty will be free.
The applicable subheading for the other alloy steel plate of a width of less than 600 mm will be 7226.91.5000, HTSUS, which provides for flat-rolled products of other alloy steel, of a width of less than 600 mm: other, not further worked than hot-rolled: other: of a thickness of 4.75 mm or more. The general rate of duty will be free.
The applicable subheading for the tool steel plate of a width of more than 600 mm will be 7225.40.1180, HTSUS, which provides for flat-rolled products of other alloy steel, of a width of 600 mm or more: other, not further worked than hot-rolled, not in coils: of a thickness of 4.75 mm or more: of tool steel, other. The general rate of duty will be free.
The applicable subheading for the tool steel plate of a width of less than 600 mm, specifically stated to be a minimum of 410 mm in width, will be 7226.91.1560, HTSUS, which provides for flat-rolled products of other alloy steel, of a width of less than 600 mm: other, not further worked than hot-rolled: of tool steel (other than high-speed steel): other: of a width of 300 mm or more, other. The general rate of duty will be free.
You have asked whether this product is subject to antidumping duties or countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at http://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov (click on “Antidumping and Countervailing Duty” under “Popular Topics” at the top of the screen), and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at http://addcvd.cbp.gov/.
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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Deborah C. Marinucci
Acting Director
National Commodity Specialist Division