Mr. Semion Sitkarev
Spectra Interpac
Zelenaya Street 10
Kostroma, Russia 156000

RE: The tariff classification of steel strapping from Russia

Dear Mr. Sitkarev:

In your letter dated June 20, 2018, you requested a tariff classification ruling.

The product to be imported is cold-rolled nonalloy steel strapping with a carbon content ranging from 0.14% to 0.18 %. This strapping, which is used for transporting and fastening packages, will be imported in coils of successively superimposed layers or spirally oscillated coils with thicknesses ranging from 0.40 mm to 1.30 mm and widths ranging from 12.7 mm to 31.75 mm. You indicate that the strapping will be either oxidized and waxed or oxidized, painted and waxed.

Steel strapping imported in coils of successively superimposed layers meets the definition of flat-rolled products in Chapter 72, Note 1. (k), Harmonized Tariff Schedule of the United States (HTSUS), whereas steel strapping imported in spirally oscillated coils, that is, wound back and forth across a spool, meets the definition of wire in Chapter 72, Note 1. (o), HTSUS.

The applicable subheading for the steel strapping in coils of successively superimposed layers will be 7212.40.1000, HTSUS, 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 free.

The applicable subheading for the steel strapping in spirally oscillated coils will be 7217.90.5030, HTSUS, 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 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, Presidential proclamations 9704 and 9705 imposed 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 HTSUS subheadings 7212.40.1000 and 7217.90.5030 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