CLA-2-84:OT:RR:NC:N1:104
Ms. Bridget K. Rodriguez
Cameron, a Schlumberger Company
3505 West Sam Houston Pkwy N
Houston, TX 77043
RE: The tariff classification of High and Low Pressure Riser Assemblies from France
Dear Ms. Rodriguez:
In your letter dated January 10, 2019, you requested a tariff classification ruling.
The High Pressure Riser Assembly, Part Number 2113178-22 and the Low Pressure Riser Assembly, Part Number 2232046-03, are designed for use in drilling operations. The High-Pressure Riser Assembly is used to connect the wellhead to the BOP stack. It contains wellbore fluids and transfers drilling cutting to the surface. The assembly is said to be used on a drilling platform in shallow water. The Low-Pressure Riser Assembly connects the subsea pipeline to the floating platform system.
In your letter, you propose classifying the assemblies under subheading 8479.89.9499, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other”. However, the riser assemblies are not classifiable under heading 8479 as they are more specifically provided for elsewhere in Chapter 84.
The applicable subheading for the High Pressure Riser Assembly, Part Number 2113178-22 and the Low Pressure Riser Assembly, Part Number 2232046-03, imported as complete assemblies, will be 8431.43.4000, HTSUS, which provides for for “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8426, 8429 or 8430: Parts for boring or sinking machinery of subheading 8430.41 or 8430.49: Of offshore oil and natural gas drilling and production platforms”. 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 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 Patricia O’Donnell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division