CLA-2-90:OT:RR:NC:N1:105

Mr. Peter M. Zubrin
STTAS, USP Company
300 Galleria Officentre, Suite 400
Southfield MI 48034

RE: The tariff classification of a center hub and end plates from China

Dear Mr. Zubrin:

In your letter dated December 12, 2018, on behalf of Ashcroft, Inc. you requested a tariff classification ruling on parts of an “isolation ring”. Samples, photographs and descriptive literature were submitted for our review.

The parts under consideration are identified as two identical “end plates” and a “center hub”. You have stated that these are used in the production of an isolation ring. The isolation ring is used as an accessory to a pressure measurement instrument that allows pressure in a piping system to be measured. Typically, the isolation ring is installed between two flanges in a piping system. When attached to a pressure measurement instrument, the isolation ring insulates the instrument from the pressurized medium. It thus transmits the pressure in a pipe to the instrument without the need to drill/weld a branch connection.

The end plates are machined from bar stock and are made from carbon steel or stainless steel, depending on the application. The center hub is also machined from bar stock and typically made from stainless steel. The end plates are affixed to the center hub using screws. A pressure measurement instrument mounts directly to the hub. You have stated that the center hub and end plates are custom-made parts and have no use outside of an isolation ring.

The applicable subheading for the end plates and center hub will be 9026.90.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts and accessories of instruments and apparatus for measuring or checking the flow, level, pressure or other variables of liquids or gases...other. The rate of duty will be free. Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS.  The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS.  Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974).  Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 9026.90.6000, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 9026.90.6000, HTSUS, listed above.

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 the World Wide Web at https://hts.usitc.gov/current.

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 Anthony E. Grossi at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division