CLA-2-72:OT:RR:NC:N1:117
Catherine Filkins
Kemeny Overseas Products Corp.
20 N Wacker Dr. Suite 1028
Chicago, IL 60606
RE: The tariff classification of coated tin mill products from Italy
Dear Ms. Filkins:
In your letter dated May 7, 2019 you requested a tariff classification ruling.
The products in question are electrolytic tinplate (ETP) and tin-free steel (TFS) which have been subjected to varnishing or a combination of varnishing and printing. Imported in coil form, these cold-rolled nonalloy steel coated products are available in widths ranging from 600 mm to 1200 mm.
There are three scenarios in which these tin mill products can be imported. The ETP and TFS can be 1) varnished on one or both sides, 2) varnished, printed, over-varnished to protect the printed design and uncoated on the reverse side and 3) varnished, printed, over-varnished to protect the printed design and varnished on the reverse side. You indicate that each of these products is varnished using a roller applied lacquer and that those products described in scenarios 2 & 3 may require multiple coatings of lacquer depending upon the end use of the product.
The applicable subheading for the coated tin mill products will be 7210.70.6090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Painted, varnished or coated with plastics: Other: Other. 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 7210.70.6090, 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