CLA-2-73:OT:RR:NC:N5:113
Sergio Fontenelle
Ernst & Young U.S. LLP
One Manhattan West, 395 9th Avenue New York, NY 10001
RE: The tariff classification of a drum back and drum front from South Korea
Dear Mr. Fontenelle:
In your letter dated May 16, 2024, you requested a tariff classification ruling on behalf of Samsung Electronics Home Appliances America, LLC. Descriptions and pictures of the drum back and drum front were submitted for our review.
The articles under consideration are two components of a washing machine drum. The first article is identified as a drum back, item number DC66-00885A. It is imported as a thin, flat, near-circular shaped, non-forged stainless-steel sheet that has a thickness of 0.5 mm. The drum back has a width of 715 mm and a length of 715 mm. The shaping of the drum back is obtained through a blanking process from a flat rectangular steel sheet, with no further surface or metal working applied post blanking. In the United States (U.S.), it undergoes additional processing steps such as trimming and flanging, which are essential for its installation into the washing machine drum.
The second item under consideration is identified as a drum front, item number DC66-00886A. It is imported as a flat stainless-steel sheet that has a thickness of 0.6 mm. The drum front measures 680 mm in width and 680 mm in length. It features a central circular hole with a 400 mm diameter. The drum front's initial form is produced through a blanking process that transforms the rectangular steel sheet into the circular shape with a hole. Following this process, no additional surface or metal working is conducted. The subsequent manufacturing stages in the U.S., including trimming and flanging, prepare the drum front to become the front portion of the washing machine drum, completing the structure necessary for the appliance's operation.
Based on the information provided, the drum back and drum front go through a process called blanking prior to importation into the U.S. You stated that Blanking is a more specific form of a generalized stamping process where a metal workpiece is removed from the primary metal strip or sheet when it is punched. The material that is removed is the new metal workpiece or blank. Therefore, both articles have been stamped with no further working or surface treatments prior to importation.
You proposed classification for the drum back and drum front in subheading 7326.19.0080, Harmonized Tariff Schedule of the United States (HTSUS). This office agrees with your proposed classification.
Heading 7326, HTSUS, provides for other articles of iron or steel.The Explanatory Notes (EN) for 73.26 state that This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.Since the drum back and drum front are not more specifically provided for in any other heading of the tariff, the drum back and drum front would be classified in heading 7326, HTSUS, because the articlesare not more specifically provided for in any other heading of the tariff.
Subheading Explanatory Note (EN) 7326.11 and 7326.19, HTSUS, states that after forging or stamping, the products of these subheadings may have been subjected to the following working or surface treatments:
Removal of burrs, runouts and other stamping defects by rough burring, grinding, hammering, chiselling or filling; removal of annealing by acid dipping; simple sandblasting; roughing or rough bleaching and other operations intended exclusively to detect flaws in the metal; application of rough coatings of graphite, oil, tar, red lead or similar products, clearly intended to protect the subjects against rust or other types of oxidation; stamping, punching, printing, etc., with simple inscriptions, such as trademarks.
We note that in condition as imported, the subject drum back and drum front have been stamped but have not been subject to a working or surface treatment other than those listed in EN Subheading Note 7326.11 and 7326.19. The subject imported articles have not been further worked as defined in the ENs, Section XV, Chapter 73, heading 73.26, Subheading EN 7326.11 and 7326.19. Therefore, the drum back and drum front would be classified in subheading 7326.19, HTSUS.
The applicable subheading for the drum back, part number DC66-00885A, and drum front, part number DC66-00886A, will be 7326.19,0080, HTSUS, which provides for other articles of iron or steel: forged or stamped, but not further worked: other. The rate of duty will be 2.9 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division