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NY I82369

June 25, 2002

CLA-2-87:RR:NC:MM:101 I82369


TARIFF NO.: 8708.29.5060

Mr. Ralph Garcia
Senior Customs Specialist
Mitsubishi Motor Sales of America, Inc.
6400 Katella Avenue
Cypress, California 90630-5208

RE: The tariff classification and status under the North American Free Trade Agreement (NAFTA), of Steel Blanks for Automotive Components from Canada or Mexico; Article 509

Dear Mr. Garcia:

In your letter dated June 6, 2002 you requested a ruling on the status of Steel Blanks for Automotive Components from Canada or Mexico under the NAFTA.

You submitted three technical drawings of steel blanks that will be imported into the United States. In the United States, the blanks will be stamped and finished into complete vehicle body components such as center members, shield plates, reinforcements and sills. You state that your ruling request covers body reinforcement blanks for the following part numbers: MR286753, Reinforcement Front Side Member MR287424, Reinforcement Center Pillar
MR297414, Reinforcement Center Member

The steel blanks will be imported and further processed into the above parts of automobile bodies. The processing operations to be performed in the United States include further stamping, removal of excess material, hole piercing and bending.

You state in your narrative that flat-rolled, hot and cold rolled, galvanized steel, in coils, measuring between .5 and 2.5 mm in thickness and a width of 1550 mm, will be imported into Canada or Mexico for the production of steel blanks for automotive components. Based on the steel specifications, the coils will be classified under HTS number 7210.49.00 upon importation into Canada or Mexico. In Canada or Mexico the steel will be uncoiled, cleaned, flattened, sheared, stretched and blanked into non-rectangular blanks for automotive components. The blanking process is described as a stamping operation from a sheet similar to a “cookie-cutter”, by which the blank is cut to the Mitsubishi required shape. The shape and measurement of each blank varies by component, however, once the blank is created, it cannot be used for any other application other than the component it was originally blanked for. Each blank is manufactured in strict accordance with Mitsubishi Motor Manufacturing of America’s technical specifications and will be used solely in the manufacture of components for Mitsubishi vehicles.

The applicable tariff provision for the Steel Blanks for Automotive Components will be 8708.29.5060, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: OtherOther. The general rate of duty will be 2.5% ad valorem.

Each of the non-originating materials used to make the vehicle body components has satisfied the changes in tariff classification required under HTSUSA General Note 12(t)/GN 12(t)87(19) A. The Steel Blanks for Automotive Components will be entitled to a Free rate of duty under the NAFTA upon compliance with all applicable laws, regulations, and agreements.

This ruling is being issued under the provisions of Part 181 of the Customs Regulations (19 C.F.R. 181).

This ruling letter is binding only as to the party to whom it is issued and may be relied on only by that party.

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 Robert DeSoucey at 646-733-3008.


Robert B. Swierupski

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