CLA-2-72:RR:NC:1:117 D84408

Mr. Michael J. Colonna
JB&S Lees Inc.
4 Edison Place
Fairfield, NJ 07004-3501

RE: The tariff classification of steel strip from England.

Dear Mr. Colonna:

In your letter dated October 27, 1998, you requested a tariff classification ruling.

You plan to import cold-rolled alloy steel strip which will ultimately be used as backing strip for bimetal and carbide tipped bandsaws. The coiled strip, which ranges from 0.020" to 0.063" in thickness and from 1/2" to 3" in width, will be supplied with a cold rolled bright (not polished) surface finish. Two different chemical analyses are provided, "Chemistry 1" which is used for the carbide tipped application and "Chemistry 2" which is used for the bimetal application. The "Chemistry 1" composition meets the Chapter 72 Note 1.(f) definition for other alloy steel. The carbon content in the "Chemistry 2" composition ranges from 0.29% to 0.33% and the chromium content ranges from 3.80% to 4.00%. Tool steel is defined in Chapter 72 Additional U.S. Note 1.(e)(ii) as an alloy steel which contains by weight not less than 0.3 percent carbon and 1.25 percent or more but less than 10.5 percent chromium. If the "Chemistry 2" composition contains not less than 0.3 percent by weight of carbon, it meets this definition of tool steel. If it contains less than 0.3 percent by weight of carbon, it meets the Chapter 72 Note 1.(f) definition for other alloy steel.

The applicable subheading for the cold-rolled tool steel strip will be 7226.92.30, Harmonized Tariff Schedule of the United States (HTS), which provides for flat-rolled products of other alloy steel, of a width of less than 600 mm, other, not further worked than cold-rolled (cold-reduced), of tool steel (other than high-speed steel), of a width of less than 300 mm. The rate of duty will be 6.4 percent ad valorem.

The applicable subheading for the cold-rolled alloy steel strip will be 7226.92.80, HTS, which provides for flat-rolled products of other alloy steel, of a width of less than 600 mm, other, not further worked than cold-rolled (cold-reduced), other, of a width of less than 300 mm, of a thickness exceeding 0.25 mm. The rate of duty will be 3.6 percent ad valorem.

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 Paula Ilardi at 212-466-5476.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division