CLA-2-72:OT:RR:NC:N1:117
Liam Jun
DSP Co., Ltd
#808 Woolim W-City
618 Sampyeong, Bundang-gu
Seongnam-si 50801
South Korea
RE: The tariff classification of an aluminum laminated steel sheet from South Korea
Dear Mr. Jun:
In your letter dated August 12, 2022, you requested a tariff classification ruling.
The product under consideration is ALUSTEEL. Referred to as an aluminum laminate, this multi-layered material consists of a .5 mm PVDF (plastic) coated aluminum alloyed sheet which is laminated via adhesive to a 1.0 mm tri-alloy coated steel backplate. The steel component known as POSMAC is comprised of a nonalloy steel substrate which is hot-dipped with a zinc, magnesium, aluminum coating and then subsequently chromate coated. You indicate that this product has a yield point ranging from 170 to 400 MPa and a tensile strength ranging from 270 to 450 MPa. ALUSTEEL will be imported in either cut lengths or in coil form and is always 600 mm or more in width.
In your request you suggest that ALUSTEEL is properly classified in subheading 7606.11.30, Harmonized Tariff Schedule of the United States (HTSUS), which provides for aluminum plates, sheets and strip, of a thickness exceeding 0.2 mm: rectangular (including square): of aluminum, not alloyed: not clad. This office disagrees. Since it is the steel portion of this composite good which predominates by weight, we find ALUSTEEL to be a product of Chapter 72 in accordance with Section XV, Note 7.
The applicable subheading for ALUSTEEL having a minimum yield point of 275 MPa will be 7210.49.0045, HTSUS, which provides for Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Of high-strength steel: Other. The rate of duty will be free.
The applicable subheading for ALUSTEEL having a minimum yield point less than 275 MPa will be 7210.49.0091, HTSUS, which provides for Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more. The rate of duty will be free.
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 7210.49.0045 and 7210.49.0091, 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 subheadings listed above.
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.
The aluminum laminated steel sheet may be subject to antidumping duties and 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 https://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/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
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 Denise Hopkins at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division