CLA-2-73:OT:RR:NC:1:117
Ms. Linda Boortz
Attorney in Fact
Aries Worldwide, Inc.
1501 E. Richey Rd.
Houston, TX 77073
RE: The tariff classification of cast stainless steel fittings from China
Dear Ms. Boortz:
In your letter dated October 24, 2012 you requested a tariff classification ruling on behalf of your client, Vortex Ventures. Schematic drawings and pictures of the fittings were included in your submission.
The products you intend to import are described as grooved stainless steel fittings and machined fabrication bodies. The fittings are further described as reducers, elbows, flange adapters and true wyes. All the fittings are cast and machined from stainless steel and have a variety of uses in different equipment. From the pictures provided, it appears that the fittings are all used to connect the bores of pipes or tubes or to connect a pipe or tube to apparatus. The ends of each fitting are machined with grooves intended to connect with similarly grooved pipe. The reducers are 6 inch x 4 inch concentric reducers, most commonly used by your client in their product recovery and dust containment assemblies. The elbows are 6 inch 90 degree elbows and 45 degree elbows most commonly used by your client’s company in their shear/mixer. The flange adapters are 6 inches in size. The 6 inch true wyes are cast stainless steel and machined having a variety of uses. The wye fitting is shaped like the letter Y and has three openings all of which are grooved on the exterior ends of the fittings and most commonly used by your client company in their dust containment assembly.
The applicable subheading for the cast stainless steel reducers, elbows, flange adapters and wyes will be 7307.19.9040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves) of iron or steel: cast fittings: other, other, other: grooved-end fittings (including grooved couplings). The rate of duty will be 6.2 percent ad valorem.
Your inquiry does not provide enough information for us to give a classification ruling on the machined fabrication bodies. Your request for a classification ruling should include the following information:
Regarding the sentence that reads “These parts can be sold to fit other equipment or machinery …”, what precisely is meant by “other equipment”? Please elaborate. Do you mean the parts are used (1) in other mixers similar to the Vortex Ventures equipment but made by other companies or (2) interchangeably in other machines that are non-mixers? If the latter, indicate the specific machines/equipment. Are these parts generic in nature or designed specifically for use in mixers/premixers? What specific features limit their use to only mixers/premixers?
Include pictures identifying the pieces enumerated, labeled exploded views, a full physical description of each piece and its function.
Include descriptive literature on the Lobestar Shear/Mixer. Submitted data sheet includes phrases such as “custom blending” and “product feed”. What specific features limit this machine to use with cement only? Can it also be used to mix drilling fluid or mud? Is the mixer (1) a stand-alone mixer, (2) portable or (3) mounted on a trailer or truck chassis? Explain shearing process. How is the material sheared? Does this unit mix/shear through centrifugal action?
What is the function of the eductor? How does it work? Is pressure or vacuum involved?
Are items 5 through 7, inclusive, ready for use when imported? Is further machining/manufacturing required subsequent to importation or are these parts joined to the other components through simple assembly?
The descriptions for items 5 through 7 contain company specific abbreviations such as “CONN SS”, “STD SS” and “VSLD 304SS CSTG W/LBL PL”. In layman’s terms, what do these abbreviations mean?
What comprises the “body”? Is it only the outer housing? If not, please explain what specific components are included in the “body”.
What does the designation “Universal T” signify?
Item 5 is said to be the body of a premixer and item 6 the body of the eductor. Where is item 7 used? Is it the body of the V-Slide Dust Containment Assembly? Is the V-Slide’s function to filter or purify gases or liquids? Does it contain filters? Include description of unit’s method of operation. What type of filter media does it employ?
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Mary Ellen Laker at (646) 733-3020.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division