CLA-2-72:OT:RR:NC:N1:117
Paul Vroman
DHL Global Forwarding
2660 20th St.
Port Huron, MI 48060
RE: The tariff classification of steel products from the United Kingdom
Dear Mr. Vroman:
In your letter dated May 15, 2019, on behalf of Somers Forge Ltd., you requested a tariff classification ruling. Representative photos were included with your request.
The items under consideration are identified as “Rough Forgings”, “Semifinished Products” and “Finished Products”. Each of these goods is comprised of alloy steel and is said to represent die keys at different stages of manufacture.
The “Rough Forgings” are produced in a two-stage forging operation. According to the information provided, an ingot is first forged into a usable billet, cut to the proper forge weight and subsequently forged into a “Rough Forging”. Imported in material lengths, these forgings are approximately square in cross-section with bull-nosed ends.
Manufactured from the forgings described above, the “Semifinished Products” are rough machined to remove the forging scale, sawn to remove the rounded edges bringing the length down to approximately .25”- .50” over finish and milled to reduce the size closer to that of the finished product. These bars will have a rectangular cross-section and will be imported in material lengths. Although you describe these products as square, based on the reported dimensions, these products are, in fact, rectangular as all four sides of the product are not equal.
The “Finished Products” at the time of importation are finished die keys identifiable as components designed for use principally with the Bêché HG and DG Series Counterblow Hammers. The die keys are tool holders used in forging hammers and presses to hold the upper and lower dies in place, acting as wedges to hold the dies securely in place.
You suggest classification of the “Rough Forgings” in subheading 7228.40.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or nonalloy steel: Other bars and rods, not further worked than forged. However, these products have neither been advanced beyond the forging stage nor produced to bar specifications.
The applicable subheading for the “Rough Forgings” will be 7224.90.0045, HTSUS, which provides for Other alloy steel in ingots or other primary forms; semi-finished products of other alloy steel: Other: Other: Other: Of rectangular (including square) cross section: Having a width less than four times the thickness. The rate of duty will be free.
The applicable subheading for the “Semifinished Products” will be 7228.60.8000, HTSUS, which provides for Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or nonalloy steel: Other bars and rods: Other: Cold-formed. The rate of duty will be free.
The applicable subheading for the “Finished Products” will be 8466.10.0110, HTSUS, which provides for “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for machines tools; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Tool holders for forming-type or cutting-type dies.” The duty rate will be 3.9 percent ad valorem.
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 7224.90.0045 and 7228.60.8000, 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
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