CLA-2-72:OT:RR:NC:N1:117
Mr. James R. Hewett
Cascade Corporation
2201 NE 201st Ave.
Fairview, OR 97024
RE: The tariff classification of steel frame profiles from Germany
Dear Mr. Hewett:
In your letter dated March 30, 2018, you requested a tariff classification ruling.
The products to be imported, identified as part numbers SK-7377, SK-7430, SK-7310 and SK-7601, are hot-extruded nonalloy steel frame profiles that will be used in the manufacture of Cascade G/J series sliding arm forklift truck attachments. You indicate that after importation each profile is further machined, assembled into a frame and then painted at your domestic manufacturing facility. The painted frame is then made into a sliding arm clamp attachment.
In your letter, you propose classifying the profiles in subheading 8431.39.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8428: Other … Other: Other”. You state that, after each profile is received at your domestic manufacturing facility, it undergoes further machining operations before being assembled into a frame and then painted. In this office’s opinion, the hot-extruded profile, in its imported condition, is a semi-manufacture not yet having the essential character of a finished part. Thus, classification in subheading 8431.39.0080, HTSUS, would not be appropriate.
The applicable subheading for the hot-extruded nonalloy steel profiles will be 7216.50.0000, HTSUS, which provides for angles, shapes and sections of iron or nonalloy steel, other angles, shapes and sections, not further worked than hot-rolled, hot-drawn or extruded. 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 the 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,
Steven A. Mack
Director
National Commodity Specialist Division