CLA-2-84:OT:RR:NC:1:104
Ms. Sandra Liss Friedman
Ms. Cortney O’Toole Morgan
Barnes, Richardson & Colburn
475 Park Avenue South
New York, NY 10016
RE: The tariff classification of drilling and fishing jars from the United Kingdom and Canada
Dear Ms. Friedman and Ms. Morgan:
In your letter dated September 21, 2009 on behalf of Weatherford US, LP you requested a tariff classification ruling.
The five jars in question are composed of alloy steel. These downhole tools are used to deliver heavy blows to objects in the borehole or retrieve equipment in a well. The jarring force delivered by a jar’s hammer frees stuck objects such as pipe or bits. The jars, which operate either mechanically or hydraulically, are described as follows:
(1) The Dailey® L.I. Mechanical Drilling Jar (“MDJ”) is a mechanical drilling jar incorporating a spring-loaded trigger system. The jar is designed to free stuck pipe in all conventional non-deviated oil and gas wells. It features a mechanical tripping system that provides immediate triggering once the required overpull is reached.
(2) The Dailey® Hydraulic Drilling Jar (“HDJ”) is a double-acting hydraulic drilling jar designed for variable hitting loads. It features a triggering check valve which controls the release of fluid from the pressure chamber. The “HDJ” may be used in a variety of applications such as high-angle drill strings and conventional and deviated oil and gas wells.
(3) The Dailey® No Torque Drilling Jar (“DNT”) is a double-acting mechanical drilling jar designed to eliminate torque problems associated with hole drag in high-angle drill strings. It incorporates the spring-loaded roller trigger system of the “MDJ” and the one-piece spline mandrel design of the “HDJ”.
(4) The Dailey® JH Double-Acting Hydraulic Drilling Jar (“HJ”) provides immediate jarring in either direction to free stuck pipe or bits. It features a check valve which controls the release of fluid from the pressure chamber.
(5) The Dailey® Hydraulic Fishing Jar (“HFJ”) features a time-delay/mechanical trigger system. It may be used in all fishing, coring, washover and other applications requiring delivery of an upward impact to a stuck point, tight spot or breakage of a core before retrieval from the well bore. The “HFJ” is installed in the fishing string for downhole use.
Drilling jars “MDJ”, “HDJ”, “DNT” and “HJ” are designed for the purpose of remedying a situation of the drill string being stuck while down hole. According to the information supplied, drilling jars “MDJ”, “HDJ” and “DNT” are installed in the drill string when in use. According to further information emailed to this office by you, drilling jar “HJ” is also installed in the drill string when in use.
In your submission, you suggest four possible classifications, i.e., heading 7306, heading 7326, heading 8431 and heading 8479.
Heading 7306, Harmonized Tariff Schedule of the United States (HTSUS), provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel. Drilling and fishing jars are not classifiable in heading 7306, HTSUS, because they are made up into specific identifiable articles.
The subject drilling and fishing jars are not classified in heading 7326, HTSUS, which provides for other articles of iron or steel. The items are more specifically provided for in another heading of the tariff.
The applicable subheading for the drilling jars “MDJ”, “HDJ”, “DNT” and “HJ” will be 8431.43.8060, HTSUS, which provides for parts…for boring or sinking machinery of subheading…8430.49.: other, of oil and gas field machinery: other The rate of duty will be free.
The applicable subheading for the hydraulic fishing jar “HFJ” will be 8479.89.9850, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; 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