CLA-2-72:S:N:N1:117 889448

Mr. Jonathan M. Fee
Grunfeld, Desiderio, Lebowitz & Silverman
1201 West Peachtree Street, N.E.
Suite 4860
Atlanta, Georgia 30309

RE: The tariff classification of clicker die steel from Austria.

Dear Mr. Fee:

In your letter dated August 13, 1993 on behalf of Viking Products, Inc., you requested a tariff classification ruling.

The imported product is known as clicker die steel. Clicker die steel is made by cold-rolling hot-rolled nonalloy strip steel to the desired thickness. The cold-rolling process includes "profile rolling". The profile rolling gives the product a non- rectangular, tapered cross sectional shape and can also form ridges and grooves which run along the length of the products. Some typical dimensions (width X thickness) of the clicker die steel are 32 X 4 mm and 19 X 3 mm. After the cold-rolling operation, the steel is hardened and tempered and the edge or edges are ground to provide sharpened "cutting bevels". The clicker die steel is imported in material lengths (cut lengths). After importation it is cut to the required length and bent to form the desired shape of cutting die. The cutting dies will be used in a specialty stamping machine known as a "die cutting press" or "clicker". The most common types of clicker die steel imported by Viking are designated by the following product codes: BETR, BD, PZA, BET and BDQ. The products designated BD and PZA have cross sections in the shape of convex polygons and therefore meet the definition for other bars and rods in Chapter 72 Note 1.(m). The products designated BETR, BET and BDQ have cross sections in the shape of concave polygons and therefore meet the definition for angles, shapes and sections in Chapter 72 Note 1.(n). The clicker die steel contains, by weight, 0.48 percent of carbon. The applicable subheading for the clicker die steel having cross sections in the shape of convex polygons will be 7215.30.00, Harmonized Tariff Schedule of the United States (HTS), which provides for other bars and rods of iron or nonalloy steel, other, not further worked than cold-formed or cold-finished, containing by weight 0.25 percent or more but less than 0.6 percent of carbon. The rate of duty will be 7.5 percent ad valorem. The applicable subheading for the clicker die steel having cross sections in the shape of concave polygons will be 7216.60.00, HTS, which provides for angles, shapes and sections of iron or nonalloy steel, not further worked than cold-formed or cold- finished. The rate of duty will be 4.9 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Sincerely,

Jean F. Maguire
Area Director
New York Seaport