Ms. Anita K. Lee
Trade Compliance Supervisor
Marubeni America Corporation
375 Lexington Avenue, 6th Floor
New York, NY 10017

RE: The tariff classification of unmachined impregnated re-baked carbon electrode rod semimanufactures from China.

Dear Ms. Lee:

In your letter dated June 6, 2009, you requested a tariff classification ruling for re-baked carbon rods. You provided a chemical composition of the product as follows: 99.5% Carbon, 0.5% Ash.

In China, crushed petroleum coke, coal tar pitch, carbon and other binders are mixed, heated and extruded into carbon paste cylinders called green electrodes, and then baked at a temperature in excess of 1000o C to transform the carbon paste into hard carbon. Next, they are removed from the furnace, surface cleaned and placed into shells for pitch impregnation to enhance the properties in the electrodes. Finally, the impregnated carbon electrode rods are re-baked at 700ÂșC to convert the impregnated pitch in the electrodes into carbon. The unmachined impregnated re-baked carbon electrode rod semimanufactures will be exported from China to the United States for manufacture into graphite electrode rods.

The applicable subheading for the unmachined impregnated re-baked carbon electrode rod semimanufactures will be 3801.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other preparations based on graphite or other carbon in the form of pastes, blocks, plates or other semimanufactures. The rate of duty will be 4.9% 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 World Wide Web at

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 Frank Cantone at (646) 733-3038.


Robert B. Swierupski
National Commodity Specialist Division