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NY N018396

November 6, 2007



TARIFF NO.: 8455.22.0000

Mr. Daniel Cannistra
PricewaterhouseCoopers LLP
1301 K St., NW
Suite 800W
Washington, DC 20005-3333

RE: The tariff classification of a rolling mill line from France

Dear Mr. Cannistra:

In your letter dated October 9, 2007 on behalf of Metrod (Malaysia) Berhad you requested a tariff classification ruling.

The “422/150 HC 5-Stand Tandem Rolling Mill Line” processes copper round drawn wire into rectangular wire with rolled edges. Pre-drawn round copper wire is mounted on the pay-off stand. The round wire passes through the first flat rolling stand to be formed into rectangular wire. During all the reduction processes, the wire and rollers are cooled with emulsion. The following upright rolling stand brings the dimension of the rectangular wire to a determined dimension by means of profiled upright rollers. The wire passes through subsequent rolling stands to shape the wire to its final radii according to the customer’s specification. Any residual emulsion is blown off with compressed air. An automatic, optical measuring device verifies that the finished wire meets all predetermined tolerances. Finally, finished wires are wound on take-up stands in accurate layer windings.

As listed in the submitted brochure, the line includes machines such as: Horizontal pay-off
Entry wire straightener and control dancer 5-Stand tandem wire flattening rolling mill One two-high rolling mill type B64
Two two-high rolling mills type B62
Two edger mills type E150
Tensiometers and cooling channels
Filtration system
Brushing machine type BRSB 300/2
Damper dancing unit
Take-up for spools
Complete electrical equipment
Control panels
When imported together in one shipment, the machines which comprise this tandem rolling mill line are intended to contribute together to the clearly defined function of rolling the metal and, thus, form one complete functional unit.

The applicable subheading for the above described “422/150 HC 5-Stand Tandem Rolling Mill Line”, imported complete as a functional unit in a single shipment, will be 8455.22.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Metal-rolling mills and rolls therefore; parts thereof: Other rolling mills: Cold. The rate of duty will be free.

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 Patricia O’Donnell at 646-733-3011.


Robert B. Swierupski

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