CLA-2-73:OT:RR:NC:N1:113
Mr. Daniel Cannistra
Crowell & Moring LLP
1001 Pennsylvania Avenue NW
Washington, District of Columbia 20004
RE: The tariff classification of steel fittings from Italy
Dear Mr. Cannistra:
In your letter dated June 22, 2020, on behalf of your client Metalfer S.p.A., you requested a tariff classification ruling for steel fittings. A description of the subject steel fittings was submitted for our review.
The articles under consideration are identified as steel fittings ranging from 3 15/16 to 11 13/16 inches (100-300 mm) in length with various outside diameters and thicknesses. You stated in the description of the subject merchandise that “The bevels on the steel fittings will be obtained through chamfering in accordance with...specifications. After importation into the United States, the steel fittings will be used as parts for automotive steering columns. Within the steering columns, the fittings will be used to connect the steering wheel to another steering mechanism.”
In your letter, you suggested that the steel fittings under consideration should be classified within subheading 7307.99.5045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other: other: other: of iron or nonalloy steel: other. We disagree. The fitting in the subject ruling connects a steering wheel column to an intermediate shaft with U-joint couplings. Since the product does not connect pipe of a single extruded material to pipe, pipe to hose of many materials such as rubber or pipe to an apparatus, it is precluded from classification as a pipe/tube fitting in heading 7307, HTSUS.
The applicable subheading for the steel fittings will be 7326.90.8688, 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