CLA-2-73:OT:RR:NC:N1:113
Mr. David Talley
DHI LLC
214 S. Austin Street
Brenham, TX 77833
RE: The tariff classification of sleeves and end rings for a transition coupling from China
Dear Mr. Talley:
In your letter dated November 6, 2015, you requested a tariff classification ruling. Product information and drawings for the subject sleeves and end rings were submitted for our review.
The products under consideration are described as component parts for the Style FC2A Ford Transition Coupling. The transition coupling is composed of four components which include sleeves, rings, gaskets and bolts. The two parts for which you are requesting a classification are identified as the Sleeve Wide Range Coupling Black FBE ASTM A536 GR 65-452 and the End Ring Ductile Iron Ultraflex Coupling Black FBE ASTM 536 GR 65-452. You stated that “These parts are not machined nor threaded but are coated.”
You suggested classification for the sleeves and end rings in question in subheading 7307.19.3085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tube or pipe fittings of iron or steel: cast fittings: other: ductile fittings: other, other. We do not agree. Classification as tube or pipe fittings requires that the complete fitting be imported. In this case only the sleeves and rings are being imported and they do not constitute a complete fitting capable of connecting the bores of two tubes or pipes, of closing off a tube aperture or connecting tube or pipe to another apparatus as required for classification as a tube or pipe fitting in heading 7307, HTSUS. There is not a provision in heading 7307 for classification of parts of fittings and therefore, in our opinion, classification as a fitting is not appropriate. Accordingly, the sleeves and end rings are classifiable under heading 7326, HTSUS, which provides for other articles of iron or steel.
The applicable subheading for the Sleeve Wide Range Coupling Black FBE ASTM A536 GR 65-452 and the End Ring Ductile Iron Ultraflex Coupling Black ASTM 536 GR 65-452 for the Style FC2A Ford Transition Coupling, will be 7326.90.8588, HTSUS, which provides for other articles of iron or steel, other…other. The rate of duty will be 2.9 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Ann Taub at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division