CLA-2-72:OT:RR:NC:N1:117
Patrick C. Roche
Voestalpine High Performance Metals, LLC
2505 Millenium Drive
Elgin, IL 60124
RE: The tariff classification of stainless steel unfinished die segments from Austria
Dear Mr. Roche:
In your letter dated October 23, 2025, you requested a tariff classification ruling.
The products under consideration are M390 stainless steel, unfinished die segments. Made from flat-rolled
steel sheets, the circular segments measure 160 mm in thickness, 195-215 mm in width, and 470-540 mm in
length. The die segments will undergo final production in the U.S. for integration into pill punching
machines.
In your submission, you suggest that the unfinished stainless steel die segments are properly classifiable in
subheading 8479.90.9596, Harmonized Tariff Schedule of United States (HTSUS), as parts of machines of
pill presses of heading 8479. We disagree. Although the segments have a half-circle shape and the rough
outer dimensions of the finished part, they are not recognizable as pill press parts in any way. The flat
unfinished piece has no positioning slots, drilled holes, or grooves which are required to contain and direct
the powdered media during tablet compression. Those crucial characteristics, which impart the article’s
essential character, are added only after importation. Accordingly, the die segments are not considered
unfinished parts or blanks for purposes or GRI 2(a).
Pursuant to Chapter 72, Note 1(k), flat-rolled products include articles of a shape other than rectangular or
square, of any size, are to be classified as products of a width of 600 mm or more, provided that they do not
assume the character of articles or products of other headings. As such, we find that your product is classified
in heading 7219, HTSUS.
The applicable subheading for the stainless steel unfinished die segments, as described above, will be
7219.31.0050, HTSUS, which provides for “Flat-rolled products of stainless steel, of a width of 600 mm or
more: Not further worked than cold-rolled (cold-reduced): Of a thickness of 4.75 mm or more: Not in coils.
The rate of duty will be free.
On March 12, 2025, Presidential proclamations 10895 and 10896 imposed additional tariffs on products of
steel and aluminum. Additional duties for steel and aluminum products of 50 percent are reflected in Chapter
99, heading 9903.81.87 for steel and heading 9903.85.02 for aluminum. Products classified under
subheading 7219.31.0050, HTSUS, may be subject to additional duties. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.81.87, in addition to the Chapter
72, 73 or 76 subheadings listed above.
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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. Your product falls within an excepted subheading. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.01.33, in addition to subheading
7219.31.0050, 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/current.
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
(CFR), 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 CFR 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 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 Denise Hopkins at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division