Comment Submitted by Nancy K. King, The Crosby Group Inc.

The proposed change to allow a tariff shift within Heading 7307 based on specified manufacturing processes recognizes the substantial transformation that occurs in the transition from rough forging to completed article. I submit that rough steel forgings in Heading 7326 that are subjected to the same or similar manufacturing processes also undergo a substantial transformation from rough forging to completed article. I therefore propose that the principles applied to the proposed tariff shift for HTSUS 7301-7307 be applied to HTSUS 7325-7326 to allow a tariff shift within Heading 7326 if the rough forgings are made ready for commercial use by: (a) at least one of the following processes (1) bevelling; (2) threading; (3) center or step boring; or (4) machining; and (b) at least two of the following processes: (1) heat treating; (2) recoining or resizing; (3) taper boring; (4) coating or galvanizing; (5) drilling bolt holes; or (6) burring or shot blasting Thank you for your consideration.