CLA-2-72:OT:RR:NC:N5:117
Mylene Tan
HJ Lee Company Inc.
14452 S. Avalon Blvd.
Gardena, CA 90248
RE: The tariff classification of nonalloy steel coils from China
Dear Ms. Tan:
In your letter dated August 11, 2024, you requested a tariff classification ruling on behalf of your client, Rollforming LLC.
The products under consideration are cold-rolled nonalloy steel coils. These steel coils are tin-coated and then painted on both sides with siliconized modified polyester. The coils measure 0.5 mm or 0.35 mm in thickness and are 1000 mm in width.
The applicable subheading for the nonalloy steel coils will be 7210.70.6090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Painted, varnished or coated with plastics: Other: Other. 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 subheading 7210.70.6090, 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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7210.70.6090, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 7210.70.6090, HTSUS, listed above.
Please be advised that the nonalloy steel coils may be subject to 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 (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). General information regarding the ITA and AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA's Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request is available at https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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/current.
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 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