CLA-2-74:RR:NC:1:118 E83339
7419.99.5050
Mr. Steven B. Zisser
Law Offices of Steven B. Zisser
Suite 34
2155 Paseo De Las Americas
San Diego, CA 92173
RE: The tariff classification of brass fittings, plastic push buttons and rubber o-rings
from Mexico.
Dear Mr. Zisser:
In your letter dated May 26, 1999, you requested a tariff classification ruling on behalf of your client, Legris, Inc., Mesa, AZ. You specifically stated that you do not want a determination on NAFTA eligibility at this time.
The subject items are described as push to connect fittings which are assembled in Mexico. You have categorized them by family types described as follows:
Family 1 - Designed to connect a piece of machinery or equipment to one plastic tube. Cartridge connectors can be male or female. The model numbers include 3014 (female), 3101 (male), 3114 (female), 3115 (sample enclosed - assembled and unassembled) 3136, 3171 (male), 3175 (male). Each Family 1 fitting is made up of an exterior brass body portion with interior connecting components consisting of a brass collet, brass retainer, plastic push button and rubber o-ring.
Family 2 - These fittings are designed to connect a piece of machinery or equipment to one or more plastic tubes. Metal bases are male or female. Model numbers include 3008, 3009, 3103, 3108, 32796 (sample enclosed - assembled and unassembled), 3129, 3198 and 3199. Each Family 2 fitting is made up of exterior components, which include brass base and plastic body and interior connecting components consisting of brass collet, brass retainer, plastic push button and rubber o-ring. In all cases, the brass components constitute over 80% of the articles’ total material value.
Family 3 - These fittings are designed to connect one plastic tube to one or more plastic tubes. Model numbers include 3102, 3104, 3106, 3183, 3140, 3141, 3166, 3182 and 3188. Certain models are specially designed for automotive applications, and are designated with a “DOT” (samples enclosed - 3104 and 3106, in both an assembled and unassembled condition). Each Family 3 (Non DOT fitting) is made up of an exterior plastic body and interior components, consisting of a brass collet, brass retainer, plastic push button and rubber o-ring. Each Family 3 (DOT) fitting is made up of interior connecting components consisting of a brass ferrule, brass collet, brass retainer and plastic o-ring. In all cases, the brass components constitute at least 78% of the articles’ total value.
You stated that all push to connect fittings are highly specialized fittings for pneumatic installations. Each fitting is designed for instantaneous connection and disconnection. They provide an immediate and automatic seal. The push to connect fitting is produced in a variety of shapes, sizes and designs to accommodate a variety of applications. The most important and significant feature of the fittings is its interior connecting components, which are principally made of brass. These are the components, which provide the instantaneous connection and automatic seal. You state that these components are specially designed for use in these specific fittings and serve no other purpose. Each internal connecting component has a specific use and purpose:
1) Brass Collet - which comes in various shapes and sizes is a gripping device used on the inside of the fitting to grasp and hold the tubing. The gripping function is reversible through a manual release button, which allows the tube to be removed from the fitting.
2) Brass Retainer - which comes in various shapes and sizes is used to secure and retain the collet, the manual release button and other sealing mechanisms inside the body of the fitting.
3) Plastic Manual Release Button - is designed to allow quick and immediate removal of the tube after it has been inserted. It is designed in various shapes and sizes depending upon the size of the particular fitting and tubing diameter.
4) Rubber 0-ring - is designed to seal the tube within the body of the fitting.
5) Brass Ferrule - is used to support a plastic tube, after it is inserted into the fitting. The ferrule prevents the plastic tube from collapsing and restricting the airflow. Brass ferrules are only found in fittings designed for truck and car applications. These components are only found in fittings with a “DOT” designation after the model number.
The other components of the push to connect fittings, consist of a body and/or a base. The primary function of these components is to house and support the above named connecting components. Additional information on the body and base is as follows:
1) Brass Body for the Family 1 fitting. This component is designed to house and support the connecting components, such as the brass collet, brass retainer, brass ferrule, rubber o-ring, and plastic manual release button.
2) Plastic or Brass Body for the Family 2 and Family 3 fittings. These components are designed to hold and support the connecting components such as the brass collet, brass retainer, brass ferrule, rubber o-ring, and plastic release button and also to help convey the air.
3) Brass Base for the Family 2 fittings. This component is designed to support the plastic or brass body, which contains the connecting components.
The fittings are always connected on at least one side to a solid construction pipe, tube or hose. They are never used on brake hoses for vehicles.
The applicable subheading for the fittings, models 3109A56 11DOT and 3115A56 14DOT, will be 7412.20.0035, Harmonized Tariff Schedule of the United States (HTS), which provides for copper tube or pipe fittings (for example couplings, elbows, sleeves): of copper alloys: other: of copper-zinc base alloys (brass): threaded: other. The general rate of duty will be 3% ad valorem.
The applicable subheading for the fittings, models 3106 56 00DOT and 3104 56 00DOT 14DOT, will be 7412.20.0045, HTS, which provides for copper tube or pipe fittings (for example couplings, elbows, sleeves): of copper alloys: other: of copper-zinc base alloys (brass): other. The general rate of duty will be 3% ad valorem.
The applicable subheading for the o-rings, when made of plastics, will be 3926.90.4510, HTS, which provides for other articles of plastics...gaskets, washers and other seals...o-rings. The general rate of duty will be 3.5 percent ad valorem.
The applicable subheading for the o-rings, when made of rubber, will be 4016.93.5010, HTS, which provides for other articles of vulcanized rubber other than hard rubber...gaskets, washers and other seals...o-rings. The general rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the plastic manual release buttons and plastic fitting bodies will be 3926.90.9880, HTS, which provides for other articles of plastics, other. The general rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the balance of the items in this inquiry will be 7419.99.5050, HTS, which provides for other articles of copper: other: other. The general rate of duty will be 2% ad valorem.
This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this 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 Kathy Campanelli at 212-637-7025.
Sincerely,
Robert B. Swierupski
Director
National Commodity
Specialist Division