CLA-2-73:OT:RR:NC:N1:117

Mr. Zach Parsons
ZF North America, Inc.
15811 Centennial Drive
Northville, MI 48168

RE: The tariff classification of steel tubing from Germany

Dear Mr. Parsons:

In your letter dated March 24, 2015 you requested a tariff classification ruling. A representative sample was included with your submission and will be returned to you.

The product under consideration is described as hollow steel tubing used to manufacture a drag link, a steering component used in off-highway construction equipment. This nonalloy seamless tubing measures 767 mm (approximately 30 inches) in length and has a diameter of 40 mm and a wall thickness of 5.7 mm. You indicate that the tubing is manufactured from bar that has been bored through its center. The tubing is then cold-drawn, heat treated, straightened, cut and bundled prior to importation.

You suggest classification of the steel tubing in subheading 7304.29.5015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, casing, tubing and drill pipe, of a kind used in drilling for oil or gas, other, tubing, of iron or nonalloy steel having an outside diameter not exceeding 114.3 mm, having a wall thickness not exceeding 9.5 mm. However, the subject tubing is not of a kind used in drilling for oil or gas and is more specifically provided for in subheading 7304.31, HTSUS.

The applicable subheading for the steel tubing will be 7304.31.6050, HTSUS, which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross section, of iron or nonalloy steel, cold-drawn or cold-rolled (cold-reduced), 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 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 [email protected].

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division