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NY 816112



November 22, 1995

CLA-2-72:RR:NC:MA:117 816112

CATEGORY: CLASSIFICATION

TARIFF NO.: 7210.49.00; 7212.30.50; 9802.00.60

Mr. Matthew Chang
Itochu International Trading
335 Madison Avenue
New York, NY 10017

RE: The tariff classification of galvanized steel sheet and the applicability of subheading 9802.00.60 to this product.

Dear Mr. Chang:

In your letter dated October 20, 1995, you requested a tariff classification ruling.

Hot-rolled nonalloy steel sheet in coils of U.S. origin will be exported to Greece for processing and subsequently returned to the U.S. for further processing. You ask whether the reimported steel sheet will be eligible for a partial duty exemption under subheading 9802.00.60.

Subheading 9802.00.60, Harmonized Tariff Schedule of the United States (HTS), provides that any article of metal (as defined in U.S. note 3(d) of this subchapter) manufactured in the United States or subjected to a process of manufacture in the United States, if exported for further processing, and if the exported article as processed outside the United States, or the article which results from the processing outside the United States, is returned to the United States for further processing may be entered with duty upon the value of such processing outside the United States upon compliance with Customs Regulations.

To meet the requirements of "further processing" some operation must be applied to the metal that will change its shape or form or impart new and different characteristics, which become an integral part of the metal itself.

The hot-rolled steel which is exported from the U.S. to Greece will be in coils and have thicknesses ranging from 0.254 mm to 10 mm and widths ranging from 508 mm to 1321 mm. In Greece, the steel will be subjected to the following operations: uncoiling, pickling, side-trimming, oiling, descaling, minor skin-passing, coil end-cutting, cold-reducing, cleaning, annealing, hot-dip galvanizing, recoiling and packing. When the galvanized coils are reimported into the U.S., they will be cut and formed into ductwork pipe.

In this respect, the operations performed in Greece and in the U.S. appear to satisfy both the foreign and domestic segments under subheading 9802.00.60. Accordingly, the merchandise may be entered under subheading 9802.00.60 with duty on the cost or value of the processing abroad upon compliance with the applicable regulations.

The applicable subheading for the hot-dip galvanized steel measuring 600 mm or more in width will be 7210.49.00, HTS, which provides for flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated, otherwise coated or plated with zinc, other. The rate of duty will be 5.8 percent ad valorem.

The applicable subheading for the hot-dip galvanized steel measuring less than 600 mm in width will be 7212.30.50, HTS, which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated, otherwise coated or plated with zinc, other. The rate of duty will be 5.8 percent ad valorem.

This ruling is being issued under the provisions of Section 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 212-466-5476.

Sincerely,

Roger J. Silvestri
Director

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