CLA-2-73:OT:RR:NC:N1:116
Ms. Andrea Abraham
Meeks, Sheppard, Leo & Pillsbury
4 Corporate Drive, Suite 292
Shelton, Connecticut 06484
RE: The tariff classification of carbon steel pipe and pipe fittings from Turkey
Dear Ms. Abraham:
In your letter dated September 2, 2020, you requested a tariff classification ruling on behalf of your client, Borusan Mannesmann Boru Sanayi.
The products under consideration are welded black (uncoated) and galvanized nonalloy steel pipe and pipe nipples made to ASTM A53, the Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless. According to your submission, these tubular products are threaded on both ends with wall thicknesses exceeding 2.54 mm and outside diameters ranging from 0.5 inch (12.7 mm) to 1.25 inches (31.75 mm). You indicate that some of the pipes will measure 12 inches or less in length while others will be imported in lengths ranging between 1.5 feet to 5 feet.
Cut-to-length steel pipe sections/pipe nipples measuring up to 12 inches in length are considered in the trade to be pipe fittings whereas cut-to-length steel pipe sections or “ready-cut pipe” measuring over 12 inches in length are considered to be pipe.
The applicable subheading for the welded black (uncoated) nonalloy steel pipe will be 7306.30.5032, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: other, welded, of circular cross section, of iron or nonalloy steel: having a wall thickness of 1.65 mm or more: other: other: with an outside diameter not exceeding 114.3 mm: galvanized: other. The rate of duty will be free.
The applicable subheading for the welded galvanized nonalloy steel pipe will be 7306.30.5055, HTSUS, which provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: other, welded, of circular cross section, of iron or nonalloy steel: having a wall thickness of 1.65 mm or more: other: other: with an outside diameter not exceeding 114.3 mm: other: other. The rate of duty will be free.
The applicable subheading for the welded black (uncoated) and galvanized nonalloy steel pipe nipples will be 7307.99.5015, 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: nipples. The rate of duty will be 4.3 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 at https://hts.usitc.gov/current.
The pipe 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.
On March 8, 2018, Presidential proclamations 9704 and 9705 imposed additional tariffs and quotas on a number of steel and aluminum mill products. Exemptions have been made on a temporary basis for some countries. Quantitative limitations or quotas may apply for certain exempted countries and can also be found in Chapter 99. Additional duties for steel of 25 percent and for aluminum of 10 percent are reflected in Chapter 99, subheading 9903.80.01 for steel and subheading 9903.85.01 for aluminum. Products classified under subheadings 7306.30.5032 and 7306.30.5055, HTSUS, may be subject to additional duties or quota. At the time of importation, you must report the Chapter 99 subheading applicable to your product classification in addition to the Chapter 72, 73 or 76 subheading listed above.
The Proclamations are subject to periodic amendment of the exclusions, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamations and the applicable Chapter 99 numbers.
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 Angelia Amerson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division