OT:RR:CTF:CPMMA H342446 CMD
Center Director
Machinery Center of Excellence & Expertise
U.S. Customs and Border Protection
109 Shiloh Drive, Suite 300
Laredo, TX 78045
Attn: Adrian Gonzalez, Jr., Import Specialist
RE: National Oilwell Varco: Request for Internal Advice; 19 C.F.R. § 177.11; Tariff
Classification of PFT Hub and Cap System
Dear Center Director,
This is in response to the internal advice request, dated July 31, 2024, initiated by Roberts
& Kehagiaras LLP, on behalf of National Oilwell Varco, L.P. (“NOV” or “Requestor”),
concerning the tariff classification of a “PFT Hub and Cap System.”
FACTS:
Counsel for the Requestor described the merchandise subject to this request for internal advice
as follows:
The merchandise at issue is part of the Yale® Closures line of products, consisting of a
buttwelded hub and a threaded cap (the “PFT Hub and Cap System”) which is used in oil
field applications to facilitate inspections or cleaning of piping systems, pig traps, and
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pressure vessels. The PFT Hub and Cap System is capable of horizontal, vertical, or
angled installations.
The PFT Hub and Cap System is comprised of a Hub (a fitting with a blank end on one
side and a threaded end on the other), a Cap which is attached to the Hub with a swing
arm which is then secured to the Hub via matching threads, a pressure safety device (as
required by ASME BPVC Section VIII Div 1 UG 351), and an O-ring. The merchandise
may come hinged or without hinges.
To install, the Hub is butt welded to the end of a pipe or pressure vessel, and the Cap is
connected to the Hub via the swing arm, which is then threaded onto the end of the Hub.
The threaded Cap can include additional features such as a chain, swivel, hinging arms,
and bleeder ports with instruments. The System is delivered unassembled to a given job
site.
Counsel for NOV also provided information on the Hub and Cap System, including
marketing material for the line of “Yale Quick Opening Closures,” which included diagrams and
dimension data; a sample entry packet; invoices from the manufacturer; and a mill report from
the manufacturer. The provided chemical analysis indicates that the hub and cap system is made
of nonalloy steel. After a request from CBP, NOV later provided additional information on the
manufacture and installation of the Hub and Cap System, which includes diagrams and pictures
of the product in use. The manufacturing process of the hub and cap system includes machining
of the raw forging.
ISSUE:
Whether the Hub and Cap System is classified in subheading 7307.93.3040, Harmonized
Tariff Schedule of the United States Annotated (“HTSUSA”), which provides for “Tube or pipe
fittings (for example, couplings, elbows, sleeves), or iron ot steel: Other: Butt welding fittings:
With an inside diameter of less than 360 mm: Of iron or nonalloy steel: Other,” or in subheading
7326.90.8688, HTSUSA, which provides for “Other articles of iron or steel: Other: Other: Other:
Other.”
LAW AND ANALYSIS:
Classification under the HTSUS is determined in accordance with the General Rules of
Interpretation (“GRI”). GRI 1 provides that the classification of goods shall be determined
according to the terms of the headings of the tariff schedule and any relative Section or Chapter
Notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the
headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be
applied in order. GRI 6 requires that the classification of goods in the subheadings of headings
shall be determined according to the terms of those subheadings, any related subheading notes
and to GRIs 1 through 5.
The HTSUS provisions under consideration here are as follows:
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7307 Tube or pipe fittings (for example, couplings, elbows, sleeves), or iron ot
steel:
Other:
7307.93 Butt welding fittings:
With an inside diameter of less than 360 mm:
7307.93.30 Of iron or nonalloy steel:
7307.93.3040 Other
7326 Other articles of iron or steel:
7326.90 Other
Other
7326.90.86 Other
7326.90.8688 Other
The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”)
constitute the “official interpretation of the Harmonized System” at the international level. See 54
Fed. Reg. 35127, 35128 (Aug. 23, 1989). While neither legally binding nor dispositive, the ENs
“provide a commentary on the scope of each heading” of the HTSUS and are “generally
indicative of [the] proper interpretation” of these headings. Id.
The ENs for heading 7307 state, in relevant part, the following:
This heading covers fittings of iron or steel, mainly used for connecting the bores of two
tubes together, or for connecting a tube to some other apparatus, or for closing the tube
aperture. This heading does not however cover articles used for installing pipes and tubes
but which do not form an integral part of the bore (e.g., hangers, stays and similar
supports which merely fix or support the tubes and pipes on walls, clamping or tightening
bands or collars (hose clips) used for clamping flexible tubing or hose to rigid piping,
taps, connecting pieces, etc.) (heading 73.25 or 73.26)(Emphasis in original).
The connection is obtained:
- By screwing, when using cast iron or steel threaded fittings;
- or by welding, when using butt-welding or socket-welding steel fittings. In
the case of butt-welding, the ends of the fitting and of the tubes are square cut
or chamfered;
- or by contact, when using removable steel fittings.
This heading therefore includes flat flanges and flanges with forged collars, elbows and bends and
return bends, reducers, tees, crosses, caps and plugs, lap joint stub‑ends, fittings for tubular
railings and structural elements, off sets, multi‑branch pieces, couplings or sleeves, clean out
traps, nipples, unions, clamps and collars.
The ENs for heading 73.26 state:
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This heading covers all iron or steel articles obtained by forging or punching, by cutting
or stamping or by other processes such as folding, assembling, welding, turning, milling
or perforating other than articles included in the preceding headings of this Chapter or
covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically
covered elsewhere in the Nomenclature.
Pipe fittings are not explicitly defined in the HTSUS. The ENs to heading 7307 give
some context when they explain that the heading covers fittings which are mainly used for
connecting two tubes together, connecting a tube to another apparatus, or for closing the tube
aperture. CBP has also defined a pipe fitting as “a small part used to join, adjust, or adapt other
parts, as in a system of pipes.” See Headquarters Ruling Letter (HQ) H213699, dated July 26,
2013; HQ H076723, dated November 24, 2010. The ENs for heading 7326 make clear that the
provision is a “basket” provision1, meaning that if an article is classifiable in a proceeding
provision of chapter 73, it may not be classified in heading 7326. Therefore, if the Hub and Cap
System meets the definition of a pipe fitting, then it is classified in heading 7307 and cannot be
classified in heading 7326, HTSUS.
The cap and hub system makes up a single pipe fitting consisting of two pieces, with the
purpose of closing the aperture of a pipe. The hub and the cap combine to perform the intended
function of the article and neither can be used separately to close the aperture of the pipe. The
hub and cap system meets the definition of a pipe fitting, because once the hub and cap system is
welded into place, the system is attached to the pipe and closes the aperture of the pipe.
Additionally, the ENs for heading 7307 explicitly include caps as pipe fittings. Therefore,
because the hub and cap system meets the definition of a pipe fitting in contexts where it is
attached to a pipe, it is classified in heading 7307, HTSUS, according to the principles of GRI 1.
Because the two pieces form a single pipe fitting and, when combined, function together, the two
pieces function as a single article, and thus no essential character analysis is necessary.
In their request for internal advice, NOV also asked for the classification of the hub and
cap system when not connected to a pipe, i.e., when intended for connection to a “pressure
vessel.” In New York Ruling Letter (“NY”) F87760, dated August 2, 2000, CBP classified a
quick opening closure in statistical reporting number 7326.90.8586, HTSUSA, which provides
for other articles of iron or steel, other.2 The closure resembled a hatch door and provided access
to pipeline pig traps, filters, coalescers, separators and pressure vessels. This construction is
similar to that of the hub and cap system and would perform a similar function when attached to
a pressure vessel. If the intended use of the hub and cap system at issue here is not to be attached
to a pipe, then it is, by definition, not a pipe fitting because it does not connect two ends of pipe,
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Heading 7326, HTSUS, is a general heading or basket provision, as evidenced by the word “other.” See The Item
Company v U.S., 98 F. 3d 1294, 1296 (CAFC 1996). Classification of imported merchandise in a basket provision is
only appropriate if there is no tariff category that covers the merchandise more specifically. See EM Industries v.
U.S., F. Supp. 1473, 1480 (1998) (“Basket’ or residual provisions of HTSUS headings . . . are intended as a broad
catch-all to encompass the classification of articles for which there is no more specifically applicable subheading.”). 2
Statistical reporting number 7326.90.8588 in the 2000 version of the HTSUSA is 7326.90.8688 in the 2025 version of
the HTSUSA.
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nor does it close the aperture of a pipe. Because the hub and cap system cannot be a pipe fitting
in this context, GRI 1 prevents its classification in heading 7307, HTSUS. Because there is no
other appropriate heading for the hub and cap system when not attached to a pipe, then it must be
classified in the basket provision for other articles of iron or steel, heading 7326, HTSUS. The
non-pipe fitting use of the hub and cap system would fall into heading 7326, HTSUS, because it
is not more specifically provided for in the HTSUS. In such instance, the hub and cap system is
classified in subheading 7326.90.8688, HTSUSA.
HOLDING:
By application of GRIs 1 and 6, the Hub and Cap System is classified in heading 7307,
HTSUS when intended to be attached to a pipe, and specifically in subheading 7307.93.3040,
HTSUSA, which provides for “Tube or pipe fittings (for example, couplings, elbows, sleeves), or
iron ot steel: Other: Butt welding fittings: With an inside diameter of less than 360 mm: Of iron
or nonalloy steel: Other.” The 2025 column one general duty rate is 6.2%.
When not intended to be attached to a pipe, the hub and cap system is classified in
heading 7326, HTSUS, and specifically in subheading 7326.90.8688, HTSUSA, which provides
for “Other articles of iron or steel: Other: Other: Other: Other.” The column one general duty rate
is 2.9%.
You are to mail this decision to the requestor no later than 60 days from the date of the
decision. At that time, the Office of Trade, Regulations and Rulings will make the decision
available to CBP personnel and to the public on the Customs Rulings Online Search System
(“CROSS”), at https://rulings.cbp.gov/, and other methods of public distribution.
Sincerely,
Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
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