CLA-2-87:OT:RR:E:NC:N1:101
Anita K. Lee, Trade Compliance Supervisor
Marubeni America Corporation
375 Lexington Ave, 6th Floor
New York, NY 10017-5682
RE: The tariff classification of a suspension pipe and carbon steel pipe from Thailand and Japan
Dear Ms. Lee,
In your letter dated October 31, 2008, you requested a tariff classification ruling.
The items under consideration have been identified as a Suspension Pipe (Part #s 52375-SWA-A010-20 and 52376-SWA-A010-20) and Pipe-R Cut (Part # 52391-SWA-A000-20).
The first part, the Suspension Pipe, is bolted to a flat piece of metal on the right side of the Pipe and then bolted to a flat stock that connects to a plastic stone protector connected to the body of the car. The Pipe is located at the rear suspension of a Sport Utility Vehicle (SUV). The shock absorber and brake knuckle attach to the Pipe after assembly in the United States. The operational function of the Pipe is to create suspension and wheel position control for the SUV.
The applicable classification subheading for the Suspension Pipe (Part #s 52375-SWA-A010-20 and 52376-SWA-A010-20) will be 8708.80.6590, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts…of…motor vehicles…: Suspension…parts…: Parts: Other: Other: Other.” The rate of duty will be 2.5%.
The second part, Pipe-R Cut, is a carbon steel, welded pipe made to ASTM specification A-513. Having an outside diameter of 19.1 mm and a wall thickness of 2.8 mm, this cold-rolled pipe is imported in lengths of 171.2 mm.
The applicable subheading for the Pipe-R Cut will be 7306.30.5055, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: Other, welded, of circular cross section, of iron or non-alloy steel: Having a wall thickness of 1.65 mm or more: Other: Other: With an outside diameter not exceeding 114.3 mm: Other: Other.” The rate of duty will be Free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.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 Suspension Pipe (Part #s 52375-SWA-A010-20 and 52376-SWA-A010-20), contact National Import Specialist Richard Laman at 646-733-3017. If you have any questions regarding the Pipe-R Cut (Part # 52391-SWA-A000-20), contact National Import Specialist Mary Ellen Laker at 646-733-3020.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division