CLA-2-72:RR:NC:1:117 H87847

Ms. Lois Cuddy
T.H. Weiss, Inc.
775 Atlanta South Parkway, Suite 600
Atlanta, Georgia 30349

RE: The tariff classification of steel strapping from Finland.

Dear Ms. Cuddy:

In your letter of January 2002, you requested a tariff classification ruling. Representative samples of the products to be imported were submitted with your request.

Cold-rolled painted nonalloy steel strapping containing less than 0.25 percent by weight of carbon will be imported in coil form, either in coils of successively superimposed layers or in spirally oscillated coils. The strapping material in coils of successively superimposed layers will measure 1 ¼” in width x 0.031” in thickness. The spirally oscillated strapping material will measure ¾” x 0.020”, ¾” x 0.025” and 5/8” x 0.020”.

Steel strapping in coils of successively superimposed layers meets the definition for flat-rolled products in HTS Chapter 72 Note 1. (k). Steel strapping in spirally oscillated coils, that is, wound back and forth across a spool, meets the definition for wire in HTS Chapter 72 Note 1.(o).

The applicable subheading for the cold-rolled painted steel strapping in coils of successively superimposed layers will be 7212.40.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated, painted, varnished or coated with plastics, of a width of less than 300 mm. The rate of duty will be 0.7 percent ad valorem.

The applicable subheading for the cold-rolled painted steel strapping in spirally oscillated coils will be 7217.90.5030, HTS, which provides for wire of iron or nonalloy steel, other, other, containing by weight less than 0.25 percent of carbon. The rate of duty will be 1.1 percent ad valorem.

The products that are the subject of NY ruling E86519 dated September 9, 1999, to which you refer, are described in that ruling as cold-rolled, not clad, plated or coated and are therefore distinguishable from the painted (coated) products that are the subject of this ruling. HQ ruling 957492 dated June 6, 1995, a copy of which is enclosed, discusses the classification of several types of steel strapping material that have undergone various treatments. You may find this ruling helpful.

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 646-733-3020


Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division