CLA-2-73:OT:RR:NC:N1:113
Mr. Arjun Singh
Quest Global
378 Maple Grove Drive
Oakville, N/A L6J 4V5
Canada
RE: The tariff classification of steel rails from India
Dear Mr. Singh:
In your letter dated February 18, 2020, you requested a tariff classification ruling on a steel rail. Photographs, a drawing, steel specification sheets, and installation instructions were provided for our review.
In your letter you described the product as a rail used to connect columns of other support members. You stated that “The rail component is made from ASTM A1008 Grade 80 Structural Steel cold rolled sheets which are fabricated to a specified shape through the cold forming roll-form fabrication process. The component has two hems for rigidity, multiple slots and holes, and tab cutouts for securement. This component is a finished product and requires no additional processing. The raw sheet steel is coated with a Zinc-Aluminum-Magnesium alloy coating for corrosion protection. The rail is approximately 1.6 inches tall x 1.4 inches wide x 65 inches long.”
The rail is used for placement of ballast blocks for PanelClaw’s mounting system for flat roofs. The rail is installed on the flat roof mounting system using a bolt. Once the rails are installed, the ballast blocks are put in to weigh the system down.
You suggest classification of the subject rail in subheading 7216.91.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Angles, shapes and sections of iron or nonalloy steel: Other: Obtained from flat-rolled products: Drilled, notched, punched or cambered. We disagree. Although heading 7216, allows for products that have been further worked, based on the manufacturing process described above, we find that this finished good has been advanced beyond a basic steel mill product.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division