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NY 879033




November 6, 1992

CLA-2-72:S:N:N1:117 879033

CATEGORY: CLASSIFICATION

TARIFF NO.: 7208.90.00

Mr. Vincent Bowen
Willkie Farr & Gallagher
Three Lafayette Centre
1155 21st Street, NW
Washington, D.C. 20036-3384

RE: The tariff classification of steel plates from Brazil.

Dear Mr. Bowen:

In your letter dated October 2, 1992 on behalf of Primary Steel, Inc., you requested a tariff classification ruling.

The products to be imported are nonalloy steel plates for railway or liquid propane gas (LPG) tanks. The plates will be made to ASTM Specification A516, Grade 70. ASTM Spec A516 is the Standard Specification for Pressure Vessel Plates, Carbon Steel, for Moderate-and Lower-Temperature Service. The rectangular plates which will be used to make the tank bodies will be imported in various sizes; the following are some typical dimensions: 0.4375" x 85.875" x 348.75" and 0.728" x 135.312" x 373.50". Flat steel circles to make the tank heads will also be imported. The steel circles range from 0.450" to 0.780" in thickness and from 135.3125" to 147" in diameter. The steel circles are torch cut from hot-rolled plate. The steel plates for the tank bodies are hot-rolled, cut to the required dimensions, bevelled and, in some cases, perforated.

Each shipment of steel plates will consist of the necessary number of circular and rectangular steel plates to make several tank assemblies. After importation, the steel plates will be segregated for distribution to various U.S. tank assemblers. The processing after importation consists of flanging and forming the steel circles into dish shapes and laterally bending and welding the tank body plates into rings. The fabricated tank cylinders will then be welded to the fabricated tank heads.

The applicable subheading for the hot-rolled carbon steel circles, the hot-rolled bevelled carbon steel plates and the hot- rolled perforated carbon steel plates will be 7208.90.00, Harmonized Tariff Schedule of the United States (HTS), which provides for flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, hot-rolled, not clad, plated or coated, other. The rate of duty will be 5 percent ad valorem.

You suggest in your ruling request that these hot-rolled plates should be classified as unfinished tanks in accordance with GRI 2(a). Explanatory Notes 2(a)(V) and (VII) provide some guidance on the application of GRI 2(a) to products such as those that Primary Steel, Inc. is planning to import. The classification of unfinished and unassembled goods is addressed at some length in a ruling request you initiated, HQ ruling 081999 dated
December 10, 1990.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire

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