CLA-2-84:OT:RR:E:NC:1:104
Mr. William Da Costa Hooper
FMC Technologies Inc.
1777 Gears Rd.
Houston, TX 77067
RE: The tariff classification of a tubing hanger from the United Kingdom
Dear Mr. Hooper:
In your letter dated August 17, 2009 you requested a tariff classification ruling.
The tubing hanger (“TH”) is a mechanism designed to suspend a production tubing string. During production, the tubing hanger routes production flow and hydraulic/chemical/electric downhole lines from the tree to below the tubing hanger by utilizing various hydraulic couplers, seals, a poppet and porting. The TH is locked/installed and unlocked/retrieved into the spool (tree spool, wellbore spool or tubing head spool) by a hydraulically operated tubing hanger running tool (“THRT”) or unlocked/retrieved mechanically by a tubing hanger mechanical retrieval tool (tools not included). The THRT pushes down on the tubing hanger’s locking mandrel in order to expand the lock ring. This mechanical action in turn locks the TH to the spool. You indicate that, in general, the TH is made from F6NM Stainless Steel (ASTM A182-F6NM).
In your letter, you suggest that the TH is classifiable in subheading 8431.43.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of drilling machinery. The tubing hanger is used during the production phase, post drilling and is associated in its installation with the handling of production (extraction of oil or gas) tubing and pumps. Heading 84.31 is for parts, including those of 8430 for well sinking. This is only for drilling machines. Explanatory Note 84.30 (III)(D) noted. As the tubing hanger is not a part of a drilling machine, it would be excluded from heading 84.31.
The applicable subheading for the tubing hanger described above will be 8479.89.9850, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; and parts thereof: Other machines and mechanical appliances: Other…Other…Oil and gas field wireline and downhole equipment. The rate of duty will be 2.5% 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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division