CLA-2-72:OT:RR:NC:N1:117
Christopher S. Pena
Hunton Andrews Kurth LLP
2200 Pennsylvania Avenue NW
Washington, DC 20037
RE: The tariff classification of bearing quality wire rod from Japan
Dear Mr. Pena:
In your letter dated May 6, 2019 you requested a tariff classification ruling.
The products under consideration are described as Grade AISI 52100/52100H high carbon chromium bearing quality steel wire rod having a silicon content of .15% - .35% and a molybdenum content of 0.00% - 0.10%. Imported in irregularly wound coils, these hot-rolled, annealed, pickled and phosphate coated rods are available in diameters ranging from 5.5 mm -18 mm. You indicate that the wire rod is used to create precision balls for drive shafts, ball bearings and wheel hub units for automobiles.
You have suggested classification of the subject products in subheading 7227.90.2060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel: Other: Of tool steel (other than high-speed steel): Other: Other. However, based on the chemistry provided, these rods may also be classifiable in another subheading.
The applicable subheading for the wire rod containing .18% or more of silicon and .09% or less of molybdenum will be 7227.90.2030, HTSUS, which provides for Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel: Other: Of tool steel (other than high-speed steel): Other: Of ball-bearing steel. The rate of duty will be free.
The applicable subheading for the wire rod containing less than .18% of silicon and/or more than .09% molybdenum will be 7227.90.2060, HTSUS, which provides for Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel: Other: Of tool steel (other than high-speed steel): Other: 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 the World Wide Web at https://hts.usitc.gov/current.
On March 8, 2018, Presidential proclamations 9704 and 9705 imposed additional tariffs and quotas on a number of steel and aluminum mill products. Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.01 for aluminum. Products classified under subheadings 7227.90.2030 and 7227.90.2060, HTSUS, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading listed above. The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 subheadings.
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 April Cutuli at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division