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NY 886003

JUNE 8, 1993

CLA-2-98:S:N:N1:117 886003


TARIFF NO.: 9802.00.60

Mr. Gary Chi
Sammi-AL Tech Inc.
19191 South Vermont Avenue
Suite 590
Torrance, California 90502

RE: The applicability of subheading 9802.00.60 to certain basic steel mill products.

Dear Mr. Chi:

In your letter dated May 4, 1993, you requested a tariff classification ruling.

Your ruling request concerns the applicability of subheading 9802.00.60, HTS, to cold-rolled stainless steel coils produced in Korea from U.S. hot-rolled stainless steel coils. Hot-rolled stainless steel coils, manufactured in the United States, will be sent to Korea where they will be cold-rolled. The Korean processing of the hot- rolled coils into cold-rolled coils consists of coil grinding, cold-rolling (cold-reducing), annealing, pickling and coil polishing. In your ruling request you state that, upon return to the U.S., the cold-rolled coils will be further processed by slitting to width, shearing to length, punching into circles, cutting to various shapes, coating with polyvinyl and further machining these products to make chemical equipment, kitchenware, architectural trim, sanitary fittings, tubing, dairy equipment, and various other products. You provided additional information indicating that, at a minimum, the imported cold-rolled stainless steel coils will be cut to length and either slit, punched or cut into various shapes in the U.S. In most cases, the steel will also be bent or formed into required shapes based on the end use of the product.

Subheading 9802.00.60, HTS, provides that any article of metal...manufactured in the United States or subjected to a process of manufacture in the United States, if exported for further processing, and if the exported article as processed outside the United States, or the article which results from the processing outside the United States, is returned to the United States for further processing may be entered with duty upon the value of such processing outside the United States upon compliance with Customs Regulations.

In order to meet the requirements of "further processing", some operation must be applied to the metal that will change its shape or form or impart new and different characteristics, which become an integral part of the metal itself.

In this respect, the foreign processes of cold-rolling and annealing and the U.S. processes of cutting, slitting, punching, bending and forming all appear to satisfy the requirements of both the foreign and domestic segments under subheading 9802.00.60. Accordingly, the cold-rolled stainless steel coils may be entered under subheading 9802.00.60 with duty on the cost or value of the processing abroad upon compliance with the applicable regulations.

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.


Jean F. Maguire

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