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NY N006458

February 23, 2007



TARIFF NO.: 7220.90.0015; 7607.19.6000

Ed Bagwell
Weidmann Plastics Technology North America Inc. 204 Enterprise Drive
Auburn, Alabama 36832

RE: The tariff classification of metal coils from Japan and Germany.

Dear Mr. Bagwell:

In your letter received February 7, 2007 you requested a tariff classification ruling.

You plan to import two types of metal products ultimately used as decorative foils in the automotive industry. The first item is type 304 stainless steel sheet measuring 0.2 mm in thickness, either 344.8 mm or 379.8 mm in width and imported in coils. This product is lacquered with an acrylic adhesive on one side and is covered with a blue film on the other side, which protects its brightly annealed finish during transport.

The second item is an aluminum foil which has been lacquered on one side with an epoxy urea substance and on the other side with an acrylic adhesive. Imported in coils, this product has a thickness of 100 um (0.1 mm) a measurement which includes both the metal and the coatings.

The applicable subheading for the steel coils will be 7220.90.0015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for flat-rolled products of stainless steel, of a width of less than 600 mm, other, containing more than 0.5 percent but less than 24 percent by weight of nickel, other. The rate of duty will be free.

The applicable subheading for the aluminum coils will be 7607.19.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm, not backed, other, other, other. The rate of duty will be 3 percent ad valorem.

Since the steel coils are of alloy steel, more specifically stainless steel, this merchandise cannot be classified in either heading 7210 or 7212, as you suggested as both of these provisions provide only for nonalloy steel.

You have asked whether this product is subject to antidumping duties or countervailing duties. A list of AD/CVD proceedings at the Department of Commerce (DOC) and their product coverage can be obtained from the DOC website at: http://ia.ita.doc.gov, or you may write to them at the U.S. Department of Commerce, International Trade Administration, Office of Antidumping Compliance, 14th Street and Constitution Avenue, N.W. Washington, DC 20230. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Gloria Stingone at 646-733-3020.


Robert B. Swierupski

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