CLA-2-84:OT:RR:NC:N1:164
Silas King
Air Cargo Sales Inc.
320 Crown Court
Oakdale, PA 15071
RE: The tariff classification of steel separator discs from Taiwan
Dear Mr. King:
In your letter dated May 5, 2025, you requested a tariff classification ruling for steel separator discs from
Taiwan on behalf of your client, Andritz Metals USA Inc. Technical information was submitted with your
request.
The items under consideration are described as steel separator discs for use on the overarm separator shaft of
a slitting line. After wide coils of metal are slit into narrower strips, the separator discs ensure neat and
uniform rewinding onto the recoiler component of a slitting line. As the narrow strips travel from the slitting
knives to the recoiler mandrel, the separator discs function as robust, circular spacers to maintain a fixed
distance between the slit strips, align the edges of each strip, and assist in guiding the strips under proper
tension. Each of these functions are essential to preventing lateral movement, overlapping, telescoping, and
loose winding as the strips are recoiled. The separator discs are made of hardened steel and may be
precision-ground or coated to prevent the marking or scratching of high-finish workpieces. Disc diameter and
thickness vary and are typically matched to the slitting line’s width configuration.
You suggested classifying the steel separator discs within subheading 8208.90.6000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for knives and cutting blades, for machines or for
mechanical appliances, and base metal parts thereof: other: other (including parts). We disagree. The steel
separator discs do not cut or slice the steel coil within the slitting line. Therefore, the merchandise does not
meet the terms of heading 8208, HTSUS, and classification within subheading 8208.90.6000, HTSUS, would
be incorrect.
Classification under the Harmonized Tariff Schedule of the United States is in accordance with the General
Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according
to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that
the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not
otherwise require, the remaining GRIs 2 through 6 will then be applied in order. In this case, the steel
separator discs are provided for in the terms of heading 8466, HTSUS, as parts for use solely or principally
with a machine of heading 8462 (slitting line).
The applicable subheading for the steel separator discs will be 8466.94.8585, HTSUS, which provides for
Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465…:
Other: For machines of heading 8462 or 8463: Other: Other: Other. The general rate of duty will be 4.7
percent ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8466.94.8585, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(C.F.R.), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 C.F.R. 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Paul Taylor at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division