Affirmation of NY N354221; Classification of Nonalloy Steel Prestressed Concrete (PC) Strands

H355076 June 22, 2026 OT:RR:CTF:CPMMA H355076 NAH CATEGORY: Classification TARIFF NO: 7312.10.3012 Ms. Laura Dissegna Mr. Carlo Formaggio CB Trafilati Acciai SPA Via Laghi 64 Tezze sul Brenta, 36056 Italy RE: Affirmation of NY N354221; Classification of Nonalloy Steel Prestressed Concrete (PC) Strands Dear Ms. Dissegna and Mr. Formaggio: This is in response to your request for reconsideration, dated October 29, 2025, of New York Ruling Letter (“NY”) N354221, issued on October 9, 2025, which concerns the country of origin and tariff classification of galvanized, nonalloy steel prestressed concrete (“PC”) strand under the Harmonized Tariff Schedule of the United States (“HTSUS”). For the reasons set forth below, we affirm NY N323823. In NY N354221, U.S. Customs and Border Protection (“CBP”) determined the country of origin for the 7-wire, galvanized, nonalloy steel PC strand was the United Kingdom and classified it under statistical reporting number 7312.10.3012, HTSUSA (“Annotated”), which provides for “Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded wire, ropes and cables: Stranded wire: Other: Other: For prestressing concrete: Other.” Your request for reconsideration concerns the classification of the merchandise at issue. Specifically, you assert: [Y]our customer needs to import into the United States under HTS 7312.10.3074, because it corresponds specifically for Galvanized material. Using subheading the “3074” applies because it falls under “Other.” The code you mention 7312.10.3012 is the code used for “Non-galvanized” or “Bare” PC Strand and 2 thus does not apply to our products. We kindly ask for you reconsideration to add code 7312.10.3074 to codes that can be used to import using United Kingdom Wire Rod. Statistical reporting number 7312.10.3074, HTSUSA, provides for “Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded wire, ropes and cables: Stranded wire: Other: Other: Other: Other: Galvanized: Other: Other.” There is no dispute concerning the classification of the merchandise up to the 8th digit subheading. As such, the only issue is the correct application of the terms at the tenth digit level of statistical reporting numbers. The two statistical reporting numbers comparable at the same level are “for prestressing concrete” or “other.” The merchandise at issue is galvanized, nonalloy steel PC strand in the 7-wire configuration. That type of strand is for prestressing concrete, and nothing raised either in the record or raised in this reconsideration request calls that fact into question. Therefore, “for prestressing concrete” is the term that explicitly describes the merchandise at issue and forecloses classification under “other” at the same level. As such, the merchandise at issue is identified by the statistical reporting numbers appearing under the provision “for prestressing concrete.” The merchandise is not covered in textile or other non-metallic material, leaving statistical reporting number 7312.10.3012, HTSUSA, as the only available classification. See NY N351276, dated July 22, 2025 (classifying 7-wire PC strand under statistical reporting number 7312.10.3012, HTSUSA). The terms appearing in statistical reporting numbers that fall outside of subheadings that explicitly describe the products at issue are not relevant to this analysis. The primary contention you raise to support this request for reconsideration is that the previous ruling did not consider whether the merchandise at issue was galvanized, which you contend led to an incorrect classification. However, pursuant to the facts you provided in NY N354221, the products at issue are explicitly described as galvanized in NY N354221. Statistical reporting number 7312.10.3012, HTSUSA, covers both galvanized and non-galvanized/bare merchandise. The galvanization of the merchandise was expressly considered, and the nonalloy steel PC strand in the 7-wire configuration was correctly classified. As such, CBP cannot find any error in NY N354221. In accordance with the foregoing, we affirm NY N354221, dated October 9, 2025, which correctly determined the tariff classification of the subject nonalloy steel PC strand. Sincerely, Yuliya A. Gulis, Director Commercial and Trade Facilitation Division