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NY N024451

April 1, 2008



TARIFF NO.: 7326.20.0070

Christopher Rini
Laufer Group International
20 Vesey Street, Suite 601
New York, NY 10007

RE: The tariff classification of steel double loop ties from China.

Dear Mr. Rini:

In your letter dated March 4, 2008, on behalf of American Wire Tie, you requested a tariff classification ruling.

The products to be imported are steel double loop ties. Imported in bundles of six, these ties have a 6 gauge diameter and measure 6 inches in length. The ties have multiple uses including securing bags and tying up vines.

The applicable subheading for the steel double loop ties will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent.

In your letter, you suggest classification of this product in subheading 7215.10.0080 as other bars and rods of iron or nonalloy steelnot further worked than cold-formed or cold finished. Since these ties have been looped at each end and do not have a uniform solid cross-section along their whole length, they do not conform to the in Chapter 72, Note 1(m) definition of other bars and rods and are therefore precluded from classification in Heading 7215.

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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