CLA-2-84:OT:RR:NC:N1:104

Mr. Andrew Fielding
Tube Solutions Ltd.
Unit 9, Pagefield Indusrial Estate, Miry Lane
Wigan WN67LA
United Kingdom

RE: The tariff classification of molds from China

Dear Mr. Fielding:

In your letter dated October 10, 2018 on behalf of Benteler Distribution Ltd., you requested a tariff classification ruling.

The molds are said to be used in the production of vacuum and air melted alloy and superalloy barstock. The barstock itself will be used in investment casting processes. The molds are manufactured in China and vary in size, i.e., (1) molds manufactured from cold drawn seamless steel tubes 5” OD x 3 ½” ID x 940mm long, (2) molds manufactured from cold drawn seamless steel tubes 6” OD x 4 ?1/4” ID x 940mm long and (3) molds manufactured from cold drawn seamless steel tubes 7 ½” OD x 5 ½” ID x 940mm long.

Molten alloy is poured into these steel molds under vacuum. Cooled bars are then pushed out of the steel molds. In order to get the bars in a “ready for sale” condition, the surface areas of the bars must be ground to remove any contamination. The molds are cleaned and re-used until the internal surfaces deteriorate. At that point, the molds are sold as scrap and replaced.

The applicable subheading for the above described molds will be 8454.20.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Converters, ladles, ingot molds and casting machines, of a kind used in metallurgy or in metal foundries, and parts thereof: Ingot molds and ladles … Ingot Molds: Other. The rate of duty will be free.

Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS.  The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS.  Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974).  Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 8454.20.0060, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8454.20.0060, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.

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 the World Wide Web at https://hts.usitc.gov/current.

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 [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division