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NY 874062

May 29, 1292

CLA-2-72:S:N:N1:117 874062


TARIFF NO.: 7215.30.00; 7222.20.00

Mr. Allen J. Hobratschk
Hamworthy USA, Inc./National Pump Co.
5690 Southfield Court, Suite 100
Forest Park, GA 30050

RE: The tariff classification of steel bars from various countries.

Dear Mr. Hobratschk:

In your letter dated April 13, 1992, you requested a tariff classification ruling.

The products to be imported are steel bars which will ultimately be used as drive shafts in pumps. You state that hot- rolled bars of Grade 1045 nonalloy steel and Types 316, 416, 630 and 17-4 PH stainless steel are purchased in Poland, Italy and Spain and then sent to Saudi Arabia where they are machined prior to importation into the United States. The following processing operations are performed on the hot-rolled bars in Saudi Arabia. They are turned and straightened and then cut to slightly longer lengths than are required for finished machine shafts. They then undergo a centerless grinding operation followed by a finish grinding process. The final processing operation performed in Saudi Arabia consists of polishing, which creates a bright blemish-free product known as "pump shaft quality shafting". After importation, the steel shafting is cut to the required length and threaded on one end.

The applicable subheading for the nonalloy steel bars will be 7215.30.00, Harmonized Tariff Schedule of the United States (HTS), which provides for other bars and rods of iron or nonalloy steel, other, not further worked than cold-formed or cold- finished, containing by weight 0.25 percent or more but less than 0.6 percent of carbon. The rate of duty will be 7.5 percent ad valorem.

The applicable subheading for the stainless steel bars will be 7222.20.00, HTS, which provides for other bars and rods of stainless steel, bars and rods, not further worked than cold- formed or cold-finished. The rate of duty will be 10.6 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

You don't indicate whether you also want a substantial transformation/country of origin ruling. In order to determine the country of origin of a product manufactured or produced in one country which undergoes manufacturing or processing operations in a second country, we would have to determine whether or not a substantial transformation of the product occurred in the second country. A substantial transformation occurs when, as a result of manufacturing processes, a new and different article emerges, having a distinctive name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process.

Some of the criteria we consider in determining what constitutes a substantial transformation of a product include: Cost of manufacturing or processing operations that occur in each country; the technology or skill required for each of the processing operations; the time spent on each of the processing operations; the characteristics, such as physical, metallurgical, chemical characteristics, which are established in each country; and, the uses of and product markets for the article both prior to and after the processing operations performed in the second country.

Because we must consider the criteria noted above before issuing a country of origin ruling, it is necessary for you to provide this additional information on the steel bars if you wish to receive such a ruling.


Jean F. Maguire
Area Director

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