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HQ 959101

JUNE 21, 1996

CLA-2 RR:TC:MM 959101 JAS


TARIFF NO.: 7212.50.00

Mr. K. Kumei
Sumitomo Corporation of America
345 Park Avenue
New York, NY 10154-0042

RE: Nickel Plated Perforated Steel Strip in Coils; Low Carbon Steel Strip Plated With Nickel for Use in Nickel Cadmium Batteries; Flat-Rolled Products of Iron or Nonalloy Steel, Plated or Coated; Chapter 72, Note 1(k)

Dear Mr. Kumei:

This is in response to your letter of January 19, 1995, to the Area Director of Customs, New York Seaport, concerning the classification under the Harmonized Tariff Schedule of the United States (HTSUS), of nickel plated perforated steel strip in coils, produced in Japan. Your letter, accompanied by a sample, has been referred to this office for reply. We regret the delay in responding.


The merchandise in issue is nickel plated perforated steel strip. The base material is cold-rolled low carbon (nonalloyed) steel strip. It is fed through a punching press and perforated, after which it is immersed in a nickel bath and plated with 99.9 percent pure nickel, approximately 3 microns/per side. The finished product is in coil form, approximately 480 mm wide and 60 microns thick. It will be processed after importation into a substrate for the negative electrode of industrial-type nickel cadmium rechargeable batteries.


Whether nickel-plated steel strip in coils that has been perforated remains in HTS heading 7212.


Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in accordance with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes, and provided the headings or notes do not require otherwise, according to GRIs 2 through 6.

Heading 7212, Harmonized Tariff Schedule of the United States (HTSUS), provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated. Chapter 72, Note 1(k), HTSUS, defines the term Flat-rolled products, in part, to include rolled products of solid rectangular cross section, in the form of coils of successively superimposed layers, and to include those products which have been perforated, corrugated, or polished, provided they do not thereby assume the character of articles or products of other headings (Emphasis added). We note your statement as to the product's end use. However, there is no evidence that, as imported, the nickel plated perforated steel strip in coil has the character of parts or components of nickel cadmium batteries. Therefore, the coiled product which has been perforated remains a product of heading 7212.


Under the authority of GRI 1, nickel plated perforated steel strip in coils is provided for in heading 7212. It is classifiable in subheading 7212.50.00, HTSUS, as flat-rolled products of iron or nonalloy steel, or a width of less than 600 mm, otherwise plated or coated. The rate of duty is 5.2 percent ad valorem.


John Durant, Director
Tariff Classification

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