CLA-2-73:OT:RR:NC:1:230
Mr. Paul M. Lichstein
Carpathian Industries LLC
51 Newark St.
Suite 508
Hoboken, NJ 07039
RE: The classification of conical steel drums from Italy and China
Dear Mr. Lichstein:
In your letter, dated May 12, 2017, you requested a binding classification ruling. The ruling was requested on conical steel drums. Pictures and product information were submitted for our review.
The subject drums are constructed from 0.6mm-thick steel, are conical in shape, and have a volume of 225 liters. The drums are open and are shipped with an equal number of lids and latching sealing rings. The conical shape allows for the space-saving stacking of the drums. They are designed for the storage and transport of non-hazardous materials such as fruit juices. The drums do not incorporate any mechanical or thermal equipment.
The drum tops and latching rings shipped with the drums are classifiable with the drums. The Explanatory Notes to the Harmonized System for heading 7310 specifically state that “all the containers may be equipped with tap holes, bungs, lids or other closures to facilitate filling and emptying.” The lids and sealing rings (closures) are described by this language.
The applicable subheading for the conical steel drums will be 7310.10.0010, Harmonized Tariff Schedule of the United States, which provides for Tanks, casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Of a capacity of 50 liters or more: Empty steel drums and barrels. The rate of duty will be free.
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 Laurel Duvall at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division