CLA-2-72:OT:RR:NC:1:117
Ms. Marianne Russell
Associate Production Manager
iWeiss Theatrical Solutions
815 Fairview Avenue #10
Fairview, NJ 07022
RE: The tariff classification of galvanized steel track and clamp components from China
Dear Ms. Russell:
In your letter dated January 21, 2014 you requested a tariff classification ruling.
The products you intend to import are described as galvanized steel track and clamp components to be used for theatre drapery installation. The track is stated to be a cold rolled 14 gauge alloy steel to be imported both alone and with steel clamps for rigging and installation of theatre drapery. Photographs and literature which you furnished with your submission show the track to be a profile without any attachments made to a size of 20 feet long x 2? inches wide x 2 ¾ inches high. The wall of the profile measures 0.06 inches thick. There are two connectors or pipe clamps described. The first, a cross grid connector has an adjustable bolted cross section designed to hold pipe in an overhead grid. The connector measures 4.5 inches x 4.5 inches x 4 inches. The second, a whole pipe clamp, measures approximately 6 inches long x 2 inches wide and is designed to be used for the installation of pipe and drapery in theatrical stages. It is not designed to connect pipe bore to pipe bore but as a support for the pipes in the theatre drapery system. A drawing submitted shows the clamp as part of the suspension hardware assemblies that suspend pipe or curtain track from the overhead structure.
You suggest classification of 8302.40.6050 however EN 83.02 (D)(5) indicate that “rods, tubes and bars, suitable for use as curtain or stair rods, etc. merely cut to length and drilled, remain classified according to the constituent metal”.
The applicable subheading for the steel alloy tracks when imported alone will be 7228.70.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel: angles, shapes and sections: other. The rate of duty will be free
of duty.
Your inquiry does not provide enough information for us to give a classification on the
Cross Grid Connector, Pipe Clamp and Suspension Hanger and additional information is required.
1. Provide a labelled sample of each article in its imported condition.
2. Provide pictures of each article in use.
3. Explain the use and function of the pipe grid.
4. Provide a detailed description of the use and function of the Cross Grid Connector, the Pipe Clamp and the Suspension Hanger.
You note that the Cross Grid Connector is used in the rigging and installation of steel pipe. However, the Pipe Clamp and the Suspension Hanger are used in the installation of pipe and in the installation of drapery. Explain the manner in which the Pipe Clamp and the Suspension Hanger serve these two different functions.
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,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division