CLA-2-73:OT:RR:NC:N1:113
Mrs. Cynthia A. Benway
Taco, Inc.
1160 Cranston Street
Cranston, RI 02920
RE: The tariff classification of tank pads from India
Dear Mrs. Benway:
In your letter dated June 11, 2020, you requested a tariff classification ruling for tank pads. Pictures and drawings for the tank pads were submitted for our review.
The articles under consideration are described as tank pads that are ring forgings made of carbon steel. The tank pads are available in five sizes that are identified as Items 22-546P, 700-1002P, 700-1022P, 700-1082P and 700-1142P. You stated that “A tank pad is a forged, flat ring that is machined on all sides with a ‘lip’ on the outside diameter and a lower face to serve as a backer for welding when attached to a tank. There are drilled and tapped blind holes on one face of the part. These parts are welded into various expansion tanks on either the top end or the bottom end of the tank.” The tank pads under consideration are used as components of Taco expansion tanks.
You indicated in your letter that a tank pad is needed to provide the structural reinforcement when a large hole is cut in the top or bottom head of a steel expansion tank, as the steel pad is welded into the opening. The tank pad also provides the surface to which a cover can be bolted, to provide a means of sealing the bladder into the tank assembly. You stated that the sole purpose of a tank pad is to provide a means to insert a bladder into an expansion tank and then to seal the tank with the bladder inside.
The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb.
The applicable subheading for the tank pads identified as Items 22-546P, 700-1002P, 700-1022P, 700-1082P and 700-1142P will be 7326.90.8688, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other…other. The rate of duty will be 2.9 percent ad valorem.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division