David W. Tuthill
Summit Global Trading
9500 W Bryn Mawr Ave. #400
Rosemont, IL 60018
RE: The tariff classification of nickel alloy plate from Japan
Dear Mr. Tuthill:
In your letter dated August 27, 2019 you requested a tariff classification ruling.
The merchandise in question is described as SuperAlloy UNSN08120. Based on the information provided, this hot-rolled, annealed nickel alloy product will be imported in plate form measuring 1750 mm in length, 1750 mm in width and 56 mm in thickness and as a test coupon measuring 600 mm in length, 35 mm in width and 56 mm in thickness.
The UNSN08120 chemistry indicates that this metal’s composition is primarily one of nickel, iron and chromium with either the nickel or iron content predominating by weight. Although you indicate that the subject products will have a nickel content which exceeds that of iron, according to the specification, there is a possibility that merchandise made to UNSN08120 chemistry could have an iron content which predominates by weight over that of the nickel.
The applicable subheading for the plate when the nickel predominates by weight will be 7506.20.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Nickel plates, sheets, strip and foil: Of nickel alloys: Other: Not cold-formed. The rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the plate when the iron predominates by weight will be 7219.21.0005, HTSUS, which provides for Flat-rolled products of stainless steel, of a width of 600 mm or more: Not further worked than hot-rolled, not in coils: Of a thickness exceeding 10 mm: Of high-nickel alloy steel. The rate of duty will be free.
The applicable subheading for the test coupon, when the nickel predominates by weight, will be 7505.12.3000, HTSUS, which provides for Nickel bars, rods, profiles and wire: Bars, rods and profiles: Of nickel alloys: Bars and rods: Not cold-formed. The rate of duty will 2.5 percent ad valorem.
The applicable subheading for the test coupon, when the iron predominates by weight, will be 7222.19.0006, HTSUS, which provides for Other bars and rods of stainless steel; angles, shapes and sections of stainless steel: Bars and rods, not further worked that hot-rolled, hot-drawn or extruded: Other: Other: Of high-nickel alloy steel. The rate of duty will be free.
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 9903.85.01 for aluminum. Products classified under subheadings 7219.21.0005 and 7222.19.0006, HTSUS, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading 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 subheadings.
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 https://hts.usitc.gov/current.
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 April Cutuli at [email protected]
Steven A. Mack
National Commodity Specialist Division