Mr. Richard M. Suh
Titan Global CHB, Inc.
311 E. Redondo Beach Blvd.
Gardena, CA 90248

RE: The tariff classification of perforated steel sheets from South Korea

Dear Mr. Suh:

In your letter dated May 21, 2108, you requested a tariff classification ruling on behalf of your client, Ace Steel & Perforated.

The articles under consideration are perforated steel sheets used in automobiles, agricultural machinery, mining equipment, heaters and air conditioners. These cold-rolled nonalloy steel sheets are cut-to-length and measure over 600 mm in width with thicknesses ranging from 0.53 mm to 0.55 mm.

Harmonized Tariff Schedule of the United States (HTSUS) Chapter 72 Note 1. (k) defines flat-rolled products of Chapter 72. This note states “Flat-rolled products include those with patterns in relief derived directly from rolling…and those which have been perforated, corrugated or polished, provided that they do not thereby assume the character of articles or products of other headings.”

You proposed classification for the subject cold-rolled metal sheets as other articles of iron or steel in heading 7326, Harmonized Tariff Schedule of the United States (HTSUS). Heading 7326 covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The cold-rolled metal sheets under consideration are not classifiable in heading 7326 because they are more specifically provided for in another heading of the HTSUS.

The applicable subheading for the perforated cold-rolled steel sheets will be 7209.90.0000, HTSUS, which provides for flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, cold-rolled (cold-reduced), not clad, plated or coated, other. The rate of duty will be free.

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

On March 8, 2018, President Trump proclaimed additional tariffs and quotas on a number of steel and aluminum mill products.  Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.03 for aluminum. Products classified under HTS subheading 7209.90.0000, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 number applicable to your product classification in addition to the Chapter 72, 73 or 76 number listed above. 

The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 numbers.

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 Mary Ellen Laker at [email protected]


Steven A. Mack
National Commodity Specialist Division