CBP Ruling J82920 — The tariff classification of steel discs from Germany.

Tariff classification

Headings: 7326

GRI rules applied: GRI 2(a)

Product description

The products you plan to import are steel discs. These discs have been cut from bars, annealed and rough machined. They measure 310 mm in diameter and come in lengths of 80 mm, 137 mm and 202 mm. In your letter, you mention subheadings 7228.40 and 8207.90. The subject discs are precluded from classification in 7228.40 as other bars and rods, not further worked than forged. As per the Explanatory Notes to Heading 7228, the provisions of the Explanatory Notes to headings 72.14 to 72.16 apply, mutatis mutandis, to the products of this heading. Specifically excluded from heading 7214 are pieces cut from bars and rods with the length not exceeding the greatest cross-sectional dimension. The subject merchandise also cannot be classified in 8207.90 as other interchangeable tools or parts. Since these discs are merely cut from bars and not machined into an extrusion disc until after importation, they are not considered “blanks” of tools of heading 8207. The Explanatory Notes for GRI 2(a) in addressing “blanks” state that semi-manufactures not yet having the essential shape of the finished articles (such as is generally the case with bars, discs, tubes, etc.) are not regarded as “ blanks ”.

CBP rationale

The applicable subheading for the steel discs will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other, other, other, other, other.

Full text

NY J82920 April 29, 2003 CLA-2-73:RR:NC:1:117 J82920 CATEGORY: Classification TARIFF NO.: 7326.90.8587 Mr. Carl Mussa KOG Transport, Inc. 377 Broadway New York, New York 10013 RE: The tariff classification of steel discs from Germany. Dear Mr. Mussa: In your letter dated April 1, 2003, on behalf of Konrad Machinery Corp., you requested a tariff classification ruling. The products you plan to import are steel discs. These discs have been cut from bars, annealed and rough machined. They measure 310 mm in diameter and come in lengths of 80 mm, 137 mm and 202 mm. In your letter, you mention subheadings 7228.40 and 8207.90. The subject discs are precluded from classification in 7228.40 as other bars and rods, not further worked than forged. As per the Explanatory Notes to Heading 7228, the provisions of the Explanatory Notes to headings 72.14 to 72.16 apply, mutatis mutandis, to the products of this heading. Specifically excluded from heading 7214 are pieces cut from bars and rods with the length not exceeding the greatest cross-sectional dimension. The subject merchandise also cannot be classified in 8207.90 as other interchangeable tools or parts. Since these discs are merely cut from bars and not machined into an extrusion disc until after importation, they are not considered “blanks” of tools of heading 8207. The Explanatory Notes for GRI 2(a) in addressing “blanks” state that semi-manufactures not yet having the essential shape of the finished articles (such as is generally the case with bars, discs, tubes, etc.) are not regarded as “ blanks ”. The applicable subheading for the steel discs will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem. 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 Paula Ilardi at 646-733-3020. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division

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