CLA-72-:OT:RR:NC:N1:117
Stephanie Jacobs
Rapid Cool Trading USA, Inc.
2001 South Main Street, Suite 1
Blacksburg, VA 24060
RE: The tariff classification of steel strut channels from China
Dear Ms. Jacobs:
In your letter dated April 4, 2019 you requested a tariff classification ruling. A representative sample of the slotted U-shaped channel with inturned edges was submitted with your request and will be returned to you under separate cover.
The products under consideration are various 2.5 mm thick nonalloy steel strut channels imported in lengths of 10 or 20 feet. The first channel is U-shaped with inturned edges and has slots uniformly punched along its entire length. Measuring 1 5/8 x 1 5/8, these strut channels are manufactured from mill pre-galvanized sheets. You state that they will either be punched and then roll formed to shape or roll formed to shape and then punched.
The second channel is U-shaped and measures 1 5/8 x 1 5/8. It is produced with or without holes and are formed from hot-rolled sheets. You state that these solid strut channels are roll formed and then hot-dipped galvanized, while the channels with holes are either roll formed, punched and then hot-dipped galvanized or punched, roll formed and then hot-dipped galvanized. These channels are available with holes punched uniformly down one, two or three sides.
The third channel is U-shaped and measures 1 7/8 x 1 7/8. It is produced with or without holes and is bent into shape from hot-rolled sheets. You state that these solid strut channels are bent to shape and then hot-dipped galvanized, while the channels with holes are bent to shape, punched and then hot-dipped galvanized or punched, bent to shape and then hot-dipped galvanized. These channels are available with holes punched uniformly down one, two or three sides.
The applicable subheading for the strut channels with inturned edges that are punched and then roll formed will be 7216.61.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Angles, shapes and sections of iron or nonalloy steel: Angles, shapes and sections, not further worked than cold-formed or cold-finished: Obtained from flat-rolled products. The rate of duty will be free.
The applicable subheading for the strut channels with inturned edges that are roll formed and then punched will be 7216.91.0010, HTSUS, which provides for Angles, shapes and sections of iron or nonalloy steel: Other: Cold-formed or cold-finished from flat-rolled: Drilled, notched, punched or cambered. The rate of duty will be free.
The applicable subheading for the solid U-shaped strut channels will be 7216.91.0090, HTSUS, which provides for Angles, shapes and sections of iron or nonalloy steel: Other: Cold-formed or cold-finished from flat-rolled: Other: Other. The rate of duty will be free.
The applicable subheading for the U-shaped strut channels with holes will be 7216.91.0010, HTSUS, which provides for Angles, shapes and sections of iron or nonalloy steel: Other: Cold-formed or cold-finished from flat-rolled: Drilled, notched, punched or cambered. 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.
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 subheadings 7216.61.0000, 7216.91.0010 and 7216.91.0090, 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 subheadings 7216.61.0000, 7216.91.0010 and 7216.91.0090, 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
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