CLA-2-94:RR:NC:SP:233 I82827

Mr. Vadim Chernobilsky
Hannibal Industries, Inc.
P.O. Box 58814
Los Angeles, CA 90058

RE: The tariff classification of steel rack components from China and Ukraine.

Dear Mr. Chernobilsky:

In your letter dated May 28, 2002, you requested a tariff classification ruling.

Your company has several divisions, one of which manufactures pallet racks and other storage systems. All the components of the racks are made out of steel. You fabricate and then powder coat them at your facility in the U.S. In an effort to improve efficiency and reduce cost, you have decided to import certain components. You are considering the following components:

Base plate Connector with rivets Connector without rivets

The components are stamped and/or formed out of sheet metal or plate. The rivets are installed if necessary also through stamping operation. They are designed for use with your pallet racks and storage systems. Once received, the components are welded together as required by the process and painted or powder coated in various colors. You have submitted a sample of each component with your request.

The applicable subheading for the steel rack components will be 9403.90.8040, Harmonized Tariff Schedule of the United States (HTS), which provides for other furniture and parts thereof: parts: other: other, of metal. The rate of duty will be free.

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 Lawrence Mushinske at 646-733-3036.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division