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NY A83672



June 28, 1996

CLA-2-72:RR:NC:MA:117 A83672

CATEGORY: CLASSIFICATION

TARIFF NO.: 7215.50.00

Ms. Maytee Pereira
Siegel, Mandell & Davidson
One Astor Plaza
1515 Broadway
43rd Floor
New York, New York 10036-8901

RE: The tariff classification of cold drawn steel bars from Canada.

Dear Ms. Pereira:

In your letter dated May 15th on behalf of The Torrington Company, you requested a tariff classification ruling. A representative sample of the product to be imported, along with representative samples of the product in various stages of manufacture, were submitted with your request.

The products to be imported are Grades 1026 and 1035 cold drawn steel bars. Coils of hot-rolled steel bars of circular cross section are produced by a Canadian steel manufacturer, Stelco Inc. and then sent to Canadian Drawn Steel Company (CDS). CDS cold draws the hot-rolled bars through a carbide die which changes the cross-section of the bars into a "Double D" shape, a "flattened circle" or "modified rectangle" of which two opposite sides are convex arcs and the other two opposite sides are straight and parallel to each other. The cold drawn bars are then cut into two different lengths prior to importation into the United States. After importation, the bars are subjected to several types of processing operations: broaching, piercing and vailing the ends; additionally, for one of the two cut lengths of bar, clip grooves and injection molding grooves are turned in the bars. The machined bars/shafts are then ready to be incorporated into automobile steering column assemblies.

The cold drawn bars, in their imported condition, meet the legal definition for other bars and rods in Chapter 72 Note 1.(m): "Products...which have a uniform solid cross section along their whole length in the shape of circles, segments of circles, ovals, rectangles (including squares), triangles or other convex polygons (including "flattened circles" and "modified rectangles", of which two opposite sides are convex arcs, the other two sides being straight, of equal length and parallel)...."

The applicable subheading for the cold drawn nonalloy steel bars will be 7215.50.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for other bars and rods of iron or nonalloy steel, other, not further worked than cold-formed or cold-finished, containing by weight 0.25 percent or more but less than 0.6 percent of carbon. The general rate of duty will be 6 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 212-466-5476.

Sincerely,

Roger J. Silvestri
Director

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