CLA-2-72:RR:NC:1:117 F80300
Mr. Royal Daniel
The Daniel Law Firm
P.O. Box 567
130 Ski Hill Road, Suite 210
Breckenridge, Colorado 80424
RE: The tariff classification of cold-rolled flat-rolled steel from Brazil.
Dear Mr. Daniel:
In your letter dated November 26, 1999 on behalf of Mangels Sao Bernardo S/A, you requested a tariff classification ruling. Additional information was submitted on December 20, 1999.
The product to be imported is tempered and annealed cold-rolled flat-rolled steel, mostly in coil form but some that is cut-to-length. It is assumed that the coiled steel is “in coils of successively superimposed layers” and that the cut-to-length steel meets the dimensional requirements for flat-rolled products in HTS Chapter 72 Note 1. (k). The flat-rolled steel ranges from ¼” (6.35 mm) to 19.68” (500 mm) in width and from 0.008” (0.20 mm) to 0.20” (5.08 mm) in thickness. As imported, the flat-rolled steel may be simply cold-rolled or cold-rolled with a polished, blue or sanded finish. This cold-rolled steel is produced from high-molybdenum SAE Grade 1075 steel that contains the following elements by weight:
Carbon (C ) 0.70 to 0.76%
Manganese (Mn) 0.60 to 0.80%
Silicon (Si) 0.15 to 0.30%
Molybdenum (Mo) 0.15 to 0.30%
Phosphorous (P) 0.024% max.
Sulfur (S) 0.015% max.
Aluminum (Al) 0.010% max.
The applicable subheading for the cold-rolled flat-rolled alloy steel which has not been processed beyond cold-rolling and which measures 300 mm or more in width will be 7226.92.50, 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), other, of a width of 300 mm or more. The rate of duty will be 2 percent ad valorem. Effective January 1, 2000, the rate of duty will be 1.6 percent ad valorem.
The applicable subheading for the cold-rolled flat-rolled alloy steel which has not been processed beyond cold-rolling and which measures less than 300 mm in width and 0.25 mm or less in thickness will be 7226.92.70, 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 not exceeding 0.25 mm. The rate of duty will be 2.6 percent ad valorem. Effective January 1, 2000, the rate of duty will be 2 percent ad valorem.
The applicable subheading for the cold-rolled flat-rolled alloy steel which has not been processed beyond cold-rolling and which measures less than 300 mm in width and over 0.25 mm in thickness 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 reduced 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 percent ad valorem. Effective January 1, 2000, the rate of duty will be 2.4 percent ad valorem.
The applicable subheading for the cold-rolled flat-rolled alloy steel with a polished, blue or sanded finish will be 7226.99.00, HTS, which provides for flat-rolled products of other alloy steel, of a width of less than 600 mm, other, other. The rate of duty will be 3.2 percent ad valorem. Effective January 1, 2000, the rate of duty will be 2.5 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
You refer to the Preliminary Determination in the Antidumping Investigation of Certain Cold-Rolled Flat-Rolled Carbon-Quality Steel Products from Brazil (A 351-830) and state that you believe this high-molybdenum cold-rolled steel is not included in the scope of this investigation because of the molybdenum content. Based on the information submitted, we are of the same opinion. However, Customs does not issue binding rulings on antidumping matters. The Department of Commerce issues scope rulings if it becomes necessary to obtain such a ruling.
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 212-637-7016.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division