CLA-2-73:OT:RR:NC:N1:113

Ms. Jessica Smith
Decatur Mold Tool & Engineering, Inc.
3330 N State Hwy 7
North Vernon, Indiana 47265

RE: The tariff classification of stainless steel and aluminum polish blocks from China

Dear Ms. Smith:

In your letter dated November 17, 2020, you requested a tariff classification ruling for polish blocks. Pictures and drawings of the subject blocks were submitted for our review.

The two products under consideration are described as stainless steel and aluminum machined polish blocks that are identical in size and design. Item 1 is identified as the 420 SS (48-52RC) hardened stainless steel block and item 2 is identified as the QC10 aluminum alloy block. Each item measures approximately 3.12 inches in length x 1.3 inches in width x 0.375 inches in depth. The blocks are finished articles at the time of importation. You indicated that the blocks will be used to demonstrate polishing techniques on steel or aluminum and will be used by your customers for training purposes. The student will learn what it is like to polish on different surfaces including a flat surface, a curved surface, a sharp angle and a narrow space. You stated that “Polishing the surfaces of the steel is a skill. The instructor will use these pieces to teach polishing techniques to students. They will polish these blocks and learn techniques on how to create the desired finish by buffing the steel using different items such as sandpaper, stones, or various hand tools.” The applicable subheading for the 420 SS (48-52RC) hardened stainless steel block will be 7326.90.8688, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other…other. The rate of duty will be 2.9 percent ad valorem. The applicable subheading for the QC10 aluminum alloy block will be 7616.99.5190, HTSUS, which provides for other articles of aluminum, other, other…other. The rate of duty will be 2.5 percent ad valorem. 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.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7326.90.8688 and 7616.99.5190, HTSUS, unless specifically excluded, are subject to an additional 25 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 7326.90.8688 and 7616.99.5190, HTSUS, listed above.   The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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