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NY I81312

May 31, 2002

CLA-2-72:RR:NC:1:117 I81312


TARIFF NO.: 7211.90.0000; 7217.10.2000

Mr. Cyril Laan
PrimeSource Building Products, Inc.
2115 East Belt Line Road
Carrollton, TX 75006

RE: The tariff classification of steel strapping from Taiwan or Korea.

Dear Mr. Laan:

In your letter dated April 25, 2002, you requested a tariff classification ruling. Representative samples of the products to be imported were submitted with your request.

The product to be imported is cold-rolled high tensile strength (Grades 1008-1012) and regular strength (Grade 1006) carbon steel strapping. The strapping will be imported in widths of ½ inch, 5/8 inch and ¾ inch and in thicknesses ranging from 0.020 inch to 0.023 inch. The strapping has a blued finish and will be imported either in coils of successively superimposed layers or in oscillated wound coils.

Steel strapping in coils of successively superimposed layers meets the definition for flat-rolled products in HTS Chapter 72 Note 1. (k). Flat-rolled products are defined in this note as “Rolled products of solid rectangular (other than square) cross sectionin the form ofcoils of successively superimposed layers.” Steel strapping in spirally oscillated coils, that is, wound back and forth across a spool, meets the definition for wire in HTS Chapter 72 Note 1. (o). Wire is defined in this note as “Cold-formed products in coils, of any uniform solid cross section along their whole length, which do not conform to the definition of flat-rolled products.”

The applicable subheading for the cold-rolled blued steel strapping in coils of successively superimposed layers will be 7211.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, not clad, plated or coated, other. The rate of duty will be 1 percent ad valorem.

The applicable subheading for the cold-rolled blued steel strapping in spirally oscillated coils will be 7217.10.2000, HTS, which provides for wire of iron or nonalloy steel, not plated or coated, whether or not polished, containing by weight less than 0.25 percent of carbon, flat wire, of a thickness exceeding 0.25 mm but not exceeding 1.25 mm. The rate of duty will be 0.6 percent ad valorem.

On March 5, 2002, President Bush proclaimed additional tariffs and quotas on a number of steel mill products for a period of three years. Products classified under HTS subheading 7211.90.0000, unless specifically excluded, are subject to additional duties. See subheadings 9903.72.85 through 9903.73.04, copy attached. Based upon the description of the merchandise provided in your request, the applicable Chapter 99 subheading is 9903.73.02 which currently carries an additional 30 percent ad valorem tariff. At the time of importation, you must report this Chapter 99 number in addition to the Chapter 72 number listed above.

The Proclamation is subject to periodic amendment of the exclusions, and the additional tariffs are reduced in the second and third years of the program, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamation.

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 646-733-3020.


Robert B. Swierupski

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