HQ 954183: Steel Doors; Foreign Trade Zone; Nonprivileged articles; 19 CFR 146.42 and 146.65(a)(2); 19 CFR 10.301 - 10.311

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                            HQ 954183
                          June 14, 1993


CLA-2 CO:R:C:M 954183 DWS

CATEGORY: Classification

TARIFF NO.: 7308.30.50

Mr. William J. LeClair
Trans-Border Customs Services, Inc.
One Trans-Border Drive
P.O. Box 800
Champlain, NY 12919

RE: Steel Doors; Foreign Trade Zone; Nonprivileged articles; 
    19 CFR 146.42 and 146.65(a)(2); 19 CFR 10.301 - 10.311

Dear Mr. LeClair:

     This is in response to your letter of May 4, 1993, on behalf
of Ali-Porte, concerning the classification of steel doors under
the Harmonized Tariff Schedule of the United States (HTSUS).

FACTS:

     The merchandise consists of hot dipped galvanized steel panels
cut to specific dimensions, rigid urethane or polystyrene
insulation, door handles, locks and hinges, all articles of
Canadian origin.  The components will be admitted into Foreign
Trade Zone (FTZ) #54 in nonprivileged foreign status.  While in the
FTZ, the steel panels will be punched, drilled, fabricated, and
then combined with the other articles to form steel doors.

ISSUE:

     Whether the steel doors, created from nonprivileged Canadian
articles in an FTZ, are classifiable under subheading 7308.30.50,
HTSUS, as other doors?

LAW AND ANALYSIS:

     Classification of merchandise under the HTSUS is in accordance
with the General Rules of Interpretation (GRI's), taken in order.
GRI 1 provides that classification is determined according to the
terms of the headings and any relative section or chapter notes. 
     
      Subheading 7308.30.50, HTSUS, provides for: "[d]oors, windows
and their frames and thresholds for doors: [o]ther."

     Nonprivileged foreign status is a residual category for
merchandise which does not have privileged or zone-restricted
status.  Articles composed entirely of or derived entirely from
nonprivileged merchandise are classified and appraised in their
condition at the time of constructive transfer to the Customs
territory for consumption.  See sections 146.42 and 146.65(a)(2),
Customs Regulations [19 CFR 146.42 and 146.65(a)(2)].

     Therefore, because the steel doors are created from
nonprivileged merchandise in an FTZ, they are classifiable as other
doors under subheading 7308.30.50, HTSUS.

HOLDING:

     The steel doors are classifiable under subheading 7308.30.50,
HTSUS, as other doors.  Goods classifiable under this provision,
upon meeting the requirements of sections 10.301 - 10.311, Customs
Regulations (19 CFR 10.301 - 10.311), are dutiable at 1.2 percent
ad valorem under the U.S.-Canada Free-Trade Agreement.

                           Sincerely,



                           John Durant, Director