CLA-2-73:OT:RR:NC:N5:113
Hyeon A. Kang
Raon Customs
34 Pyeongtaek 5-ro 20beon-gil Pyeongtaek-si, Gyeonggi-do 17902 South Korea
RE: The tariff classification of steel sheets from South Korea
Dear Mr. Kang:
In your letter dated November 27, 2024, you requested a tariff classification ruling on behalf of your client ILJITECH. Product descriptions and pictures were submitted for our review.
The article under consideration is pre-cut steel sheet, which is a raw material, identified as part number 64312-AR000_BLK. You indicated in your letter that prior to importation the raw material will undergo a blanking/stamping process performed in South Korea to produce the steel sheet in condition as imported into the United States. You stated the raw material “goes through press processing (blanking) with a special mold made to match the width and thickness of the steel sheet…and cutting in the process is cutting to create the necessary parts (cutting in a state where there is no identifiable shape).”
The blanking process produces individual steel sheets that measure 1680 millimeters in width by 630 millimeters in length, by 1.2 millimeters in thickness. The two parallel sides are not straight lines but have a wave shape. Along the length each steel sheet has straight edge while along the width it has a wavy pattern. This product is shipped from South Korea after several sheets are stacked and packaged. Once imported the steel sheets will be further worked and used in the manufacture of automobiles parts.
You proposed classification for part number 64312-AR000_BLK in subheading 7326.90.8688, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel: other…other. This office disagrees 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 part number 64312-AR000_BLK is not more specifically provided for in any other heading of the tariff, the steel sheet would be classified in heading 7326, HTSUS, because the articles are 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 sand blasting; 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, part number 64312-AR000_BLK has been stamped but has 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, part number 64312-AR000_BLK would be classified in subheading 7326.19, HTSUS, which provides for other articles of iron or steel: forged or stamped, but not further worked.
The applicable subheading for the steel sheet, part number 64312-AR000_BLK, 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