CLA-2-72:RR:NC:1:117 G87421

Ms. Connie Groat
Freight-Base Custom Brokers, Inc.
P.O. Box 66479
Chicago AMF, Illinois 60666

RE: The tariff classification of steel welding wire from Italy.

Dear Ms. Groat:

In your letter dated February 15, 2001 on behalf of HTP America, Inc., you requested a tariff classification ruling. A sample of the product to be imported was submitted with your request.

The product to be imported is copper coated alloy (> 0.6 % of silicon) steel wire. The wire measures 0.023” in diameter and is in coil form, wound on a spool. This wire is not flux coated.

You state that this wire will be used for welding only and not for any other purpose. You suggest that this wire is classifiable under HTS heading 8311 which provides for “Wire…electrodes and similar products of base metal…coated or cored with flux material, of a kind used for soldering, brazing, welding….”

Even though this product is used for welding, it cannot be classified under heading 8311 because it is not coated or cored with flux material, e.g. zinc chloride, ammonium chloride, borax, quartz, resin or lanolin.

The applicable subheading for the copper coated alloy steel welding wire will be 7229.20.00, Harmonized Tariff Schedule of the United States (HTS), which provides for wire of other alloy steel, of silico-manganese steel. The rate of duty will be 2.7 percent ad valorem.

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 Paula Ilardi at 212-637-7016 .

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division