CLA-2-72:OT:RR:NC:N1:117
Christopher S. Pena
Hunton Andrews Kurth LLP
2200 Pennsylvania Avenue NW
Washington, DC 20037
RE: The tariff classification of steel wire rod from Japan
Dear Mr. Pena:
In your letter dated March 21, 2019, on behalf of your client, TN Americas Holding, Inc., you requested a tariff classification ruling.
The product to be imported is described as hot-rolled bearing quality wire rod available in diameters ranging from 4.1 mm to 16 mm. Made to ASTM A295, the standard specification for High-Carbon Anti-Friction Bearing Steel, these SAE 52100 rods will have the following chemistry:
Aluminum (0.00 % to 0.05 %), Carbon (0.98% to 1.05%), Chromium (1.35% to 1.60%), Copper (0.00% to 0.20%); Iron (96.40% to 97.60%), Manganese (0.25% to 0.45%), Molybdenum (0.00% to 0.06%), Nickel (0.00% to 0.20%), Nitrogen (0.00% to 0.20%), Phosphorus (0.00% to 0.02%); Silicon (0.18% to 0.35%); Sulfur (0.00% to 0.01%) and Vanadium (0.00% to 0.10%). Based on the information provided, the rods are spheroidized annealed, pickled, phosphate coated and coiled subsequent to the rolling operation. You indicate that these rods are principally used in the manufacture of precision balls for automobile bearings.
The applicable subheading for the wire rods will be 7227.90.2030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Bars and rods, hot-rolled, in irregularly wound coils, of other alloy steel: Other: Of tool steel (other than high-speed steel): Other: Of ball- bearing steel. The rate of duty 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 the World Wide Web at https://hts.usitc.gov/current.
On March 8, 2018, Presidential proclamations 9704 and 9705 imposed additional tariffs and quotas on a number of steel and aluminum mill products. Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.01 for aluminum. Products classified under subheading 7227.90.2030, HTSUS, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading listed above. The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 subheadings.
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 April Cutuli at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division