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HQ 966400




April 24, 2003

CLA-2: RR:CR:GC 966400 DSS

CATEGORY: CLASSIFICATION

TARIFF NO.: 8207.70.30

Mr. Craig Schau
Emery Customs Brokers
6940A Engle Road
Middleburg Hts., OH 44130

RE: Classification request for samples of tungsten carbide tool blanks; HQ 966199

Dear Mr. Schau:

In your letter to the Director, National Commodity Specialist Division, New York, dated March 5, 2003, on behalf of Rogers Tool Works, Inc., you inquire as to the classification under the Harmonized Tariff Schedule of the United States (HTSUS) of certain tungsten carbide tool blanks. Your letter was forwarded to this office for reply with regard to the router bits.

FACTS:

The bulk of the articles for which you sought classification were classified in New York Ruling Letter (NY) J81908, dated April 3, 2003. Your letter was forwarded to this office for classification of part number 132707874, a sintered tungsten carbide tool blank of U.S. origin, which is to be manufactured into router bits.

In NY J81908, the Bureau of Customs and Border Protection (Customs) described the articles under consideration in relevant part:

Samples of tungsten carbide tool blanks of various grades, part numbers P71006R, P71031R, P71014R, T2587810R and 227314R have been provided. These U.S. made blanks are in the form of rods approximately 1 ½" long. The first three are 1/8" in diameter while the fourth has a ¼" diameter. The last, part number 227314R, is also approximately 1 ½" long however it consists of a 1" shank with an 1/8" diameter brazed to a ½" long rod blank of approximately 5/16" diameter which will be machined into the cutting portion of a reversed shank drill bit. All of the blanks are produced out of a carbide powder also manufactured in the U.S. You have since confirmed by your e-mail of March 31, 2003 that the blanks are made of sintered tungsten carbide. . .

At present, your client manufactures these blanks and ships them overseas where they are subject to grinding, fluting, pointing, washing, inspection, ringing and packing and labeling. The order of processing does not vary. The resulting drill bits, router bits, etc. will be used for printed circuit board production. Pointing is the cutting and grinding of the tool point. Ringing is the attaching of a plastic ring to the bit in a ring setting machine. The rings serve to identify the product by labeling and color coding. In addition, the rings can be adjusted and used as a depth gauge.

Headquarters Ruling Letter (HQ) 966199, dated April 18, 2003, provides a classification of substantially similar router bits under heading 8207, HTSUS, which provides, in part, for interchangeable tools for machine tools. That ruling classifies the router bits in subheading 8207.70.30, HTSUS, which provides for tools for milling.

The analysis applied in that ruling applies here. The LAW AND ANALYSIS section of HQ 966199 is incorporated by reference. A copy of HQ 966199 is enclosed.

HOLDING:

Under the authority of GRI 1, the router bits are provided for in heading 8207, HTSUS. The router bits are classified under subheading 8207.70.30, HTSUS, as “interchangeable tools for . . . machine tools; [t]ools for milling, and parts thereof; with cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium.” Sincerely,

John Elkins for

Myles B. Harmon,
Director

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