H250634-CROSSCustomsRulingsOnlineSearchSystem.docVIP

HQ H250634 May 4, 2015 CLA-2: OT: RR: CTF: TCM H250634 ERB CATEGORY: Classification TARIFF NO.: 7218.99.00; 2619.00.90 Area Port Director, Port of Mobile U.S. Customs and Border Protection 150 N. Royal Street, Room 3004 Mobile, AL 36602 Attn: Jack Nichols, Senior Import Specialist, and Patty Knight, Supervisory Import Specialist RE: Internal Advice Request; Tariff Classification – Outokumpu Stainless USA LLC Dear Area Port Director: This letter is in reply to your request for Internal Advice, initiated by a letter dated November 8, 2013. At issue, among other things, is the tariff classification for materials resulting from the production of stainless steel in a Foreign Trade Zone (FTZ) Subzone owned and operated by Outokumpu Stainless USA, LLC (Outokumpu). This Internal Advice also requested assistance on the acceptability of the methods of entered value determination for those materials. The instant response will only address the classification component. The other issues will be addressed under separate cover, Headquarters Ruling (HQ) H249192. A sample of the stainless steel slab at issue here was provided by Outokumpu to this office, which in turn, provided it to the National Commodity Specialist Division (NCSD) of U.S. Customs and Border Protection (CBP) for analysis. No sample of the dust was provided. Follow up communication with Outokumpu and additional information provided by them in emails dated December 18, 2014 were also used in this analysis. FACTS: In its Calvert, Alabama Foreign Trade Zone (FTZ) facility, Outokumpu produces stainless coil, hot-rolled plate, bar, and tubular products via an integrated stainless steel mill whereby recycled stainless steel is used to manufacture the final products. At issue here are two products: stainless steel slabs and stainless steel “dust”. Outokumpu’s production process for the stainless steel slabs can be described thusly: recycled metals, scrap metals, and other stainless steel metals (referred to as “c