CLA-2-73:OT:RR:E:NC:1:118

Mr. Joseph Schnitzler
Itochu Building Products Co., Inc.
660 White Plains Road
Tarrytown, NY 10591

RE: The tariff classification of a threaded foundation rod from China.

Dear Mr. Schnitzler:

In your letter dated May 7, 2009 you requested a tariff classification ruling.

You describe the instant merchandise as a threaded steel foundation rod that is ½” in diameter, 52” long and has an 8” right angle bend at one end. You have stated that the rod is fully threaded and it is used in home construction in areas prone to hurricanes. The end with the 8” bend is imbedded in a concrete block foundation. The longer end extends up thru the sole plate, bottom plate and into the void between the wall studs. A coupler connects the foundation rod to another threaded rod. This threaded rod goes up through the top plate and is attached to the roof trusses, thus holding the whole house together.

The applicable subheading for the steel threaded foundation rod will be 7318.15.5050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other screws and bolts, whether or not with their nuts or washers: studs: other: continuously threaded rod. The duty rate 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 Kathy Campanelli at (646) 733-3021.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division