CLA-2-83:OT:RR:NC:N1:113
Ms. Helen M. Cousineau
Deloitte Tax LLP
111 S. Wacker Drive
Chicago, IL 60606
RE: The tariff classification of steel wire welding consumables from India
Dear Ms. Cousineau:
In your letter dated August 15, 2018, on behalf of Superon Schweisstechnik India Ltd., you requested a tariff classification ruling. Product specifications were submitted for our review.
The products under consideration are identified in your letter as four types of steel wire welding consumables, all used as consumables in welding processes. The subject consumables are finished branded products and are not used as input raw material for any other industry. Item 1 is described as Metal in Gas (MIG) stainless steel round wire with a diameter ranging from 0.8 mm - 1.6 mm. MIG wire serves as a consumable electrode in the electronic arc welding process and is imported in spools. Item 2 is described as Tungsten Inert Gas (TIG) stainless steel round wire with a diameter ranging from 0.8 mm - 1.6 mm. TIG wire is cut into lengths of 1 meter and imported in plastic tubes. These are made of extra low carbon austenitic stainless steel. The nickel content varies, but is more than 8% and less than 20%. The TIG wire serves as a consumable filler in the gas tungsten arc welding (GTAW) welding process, but not as an electrode. Item 3 is described as Submerged Arc Welding (SAW) stainless steel round wire with low carbon content, and a diameter of 1.6 mm – 4 mm. SAW wire is imported in spools and serves as a consumable electrode in the welding process. Item 4 is described as Copper Coated Manganese Silicon (CCMS) round wires with a diameter ranging from 0.8 mm - 1.6 mm, suitable for welding with carbon dioxide. The CCMS wires are imported in spools. The steel is alloyed with metals including 0.09% carbon, 1.5% manganese and 0.9% silicon.
The MIG, TIG, and SAW wires are coated with a mix of methylene chloride and dichloroethylene, which functions as a flux material for welding. The CCMS wires do not include a chemical coating, but are coated with copper for the purpose of protecting the weld from oxidation and corrosion.
The applicable subheading for the Metal in Gas (MIG) and Submerged Arc Welding (SAW) steel wire welding consumables will be 8311.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for wire, rods, tubes, plates, electrodes and similar products of base metal or of metal carbides, coated or cored with flux material, of a kind used for soldering, brazing, welding or deposition of metal or of metal carbides; wire and rods, of agglomerated base metal powder, used for metal spraying; base metal parts thereof; coated electrodes of base metal, for electric arc-welding. The rate of duty will be free.
The applicable subheading for the Tungsten Inert Gas (TIG) will be 8311.90.0000, HTSUS, which provides for wire, rods, tubes, plates, electrodes and similar products of base metal or of metal carbides, coated or cored with flux material, of a kind used for soldering, brazing, welding or deposition of metal or of metal carbides; wire and rods, of agglomerated base metal powder, used for metal spraying; base metal parts thereof; other. The rate of duty will be free.
We require additional information in order to classify the Copper Coated Manganese Silicon wires. Please provide the chemistry of the Copper Coated Manganese Silicon round wires.
If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to Director, National Commodity Specialist Division, Customs and Border Protection, 201 Varick Street, Suite 501, New York NY 10014, attn: Binding Ruling Request. If your request was submitted electronically and the information required does not involve sending a sample, you can re-submit your request and the additional information electronically.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division