OT:RR:CTF:CPMMA H355076 NAH
TARIFF NO: 7312.10.3012
Ms. Laura Dissegna
Mr. Carlo Formaggio
CB Trafilati Acciai SPA
Via Laghi 64
Tezze sul Brenta, 36056
Italy
RE: Affirmation of NY N354221; Classification of Nonalloy Steel Prestressed Concrete (PC)
Strands
Dear Ms. Dissegna and Mr. Formaggio:
This is in response to your request for reconsideration, dated October 29, 2025, of New
York Ruling Letter (“NY”) N354221, issued on October 9, 2025, which concerns the country of
origin and tariff classification of galvanized, nonalloy steel prestressed concrete (“PC”) strand
under the Harmonized Tariff Schedule of the United States (“HTSUS”). For the reasons set forth
below, we affirm NY N323823.
In NY N354221, U.S. Customs and Border Protection (“CBP”) determined the country of
origin for the 7-wire, galvanized, nonalloy steel PC strand was the United Kingdom and
classified it under statistical reporting number 7312.10.3012, HTSUSA (“Annotated”), which
provides for “Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not
electrically insulated: Stranded wire, ropes and cables: Stranded wire: Other: Other: For
prestressing concrete: Other.”
Your request for reconsideration concerns the classification of the merchandise at issue.
Specifically, you assert:
[Y]our customer needs to import into the United States under HTS 7312.10.3074,
because it corresponds specifically for Galvanized material. Using subheading the
“3074” applies because it falls under “Other.” The code you mention
7312.10.3012 is the code used for “Non-galvanized” or “Bare” PC Strand and
thus does not apply to our products. We kindly ask for you reconsideration to add
code 7312.10.3074 to codes that can be used to import using United Kingdom
Wire Rod.
Statistical reporting number 7312.10.3074, HTSUSA, provides for “Stranded wire, ropes,
cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded
wire, ropes and cables: Stranded wire: Other: Other: Other: Other: Galvanized: Other: Other.”
There is no dispute concerning the classification of the merchandise up to the 8th digit
subheading. As such, the only issue is the correct application of the terms at the tenth digit level
of statistical reporting numbers.
The two statistical reporting numbers comparable at the same level are “for prestressing
concrete” or “other.” The merchandise at issue is galvanized, nonalloy steel PC strand in the 7-
wire configuration. That type of strand is for prestressing concrete, and nothing raised either in
the record or raised in this reconsideration request calls that fact into question. Therefore, “for
prestressing concrete” is the term that explicitly describes the merchandise at issue and
forecloses classification under “other” at the same level. As such, the merchandise at issue is
identified by the statistical reporting numbers appearing under the provision “for prestressing
concrete.” The merchandise is not covered in textile or other non-metallic material, leaving
statistical reporting number 7312.10.3012, HTSUSA, as the only available classification. See
NY N351276, dated July 22, 2025 (classifying 7-wire PC strand under statistical reporting
number 7312.10.3012, HTSUSA). The terms appearing in statistical reporting numbers that fall
outside of subheadings that explicitly describe the products at issue are not relevant to this
analysis.
The primary contention you raise to support this request for reconsideration is that the
previous ruling did not consider whether the merchandise at issue was galvanized, which you
contend led to an incorrect classification. However, pursuant to the facts you provided in NY
N354221, the products at issue are explicitly described as galvanized in NY N354221. Statistical
reporting number 7312.10.3012, HTSUSA, covers both galvanized and non-galvanized/bare
merchandise. The galvanization of the merchandise was expressly considered, and the nonalloy
steel PC strand in the 7-wire configuration was correctly classified. As such, CBP cannot find
any error in NY N354221. In accordance with the foregoing, we affirm NY N354221, dated
October 9, 2025, which correctly determined the tariff classification of the subject nonalloy steel
PC strand.
Sincerely,
Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
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