CLA-2-84:OT:RR:NC:N1:105
Jim Masloski
Customs Direct LLC
6901 W Strabane Trail
Sioux Falls, South Dakota 57106
RE: The tariff classification of the proWRAP Well Screen from Canada
Dear Mr. Masloski:
In your letter dated August 31, 2021, on behalf of your client, Variperm Canada Ltd., you requested a tariff classification ruling.
The merchandise under consideration is described as the proWRAP Well Screen, which is made of L80 pipe, cut and threaded with API BTC (Buttress Thread Coupled) coupling and pin connections. The joints of the pipe are drilled with holes and a stainless-steel sand control screen is welded on covering the holes of the pipe. The proWRAP Well Screen will be used to aid in the flow of oil, gas or water while stopping solids such as formation sand when moving the liquids from downhole to the surface.
You suggest the proWRAP Well Screen be classified in subheading 7304.29, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel: Casing, tubing and drill pipe, of a kind used in drilling for oil or gas: Other.” We disagree. As the product in question consists of pipe, pin connections, multiple drilled holes and control screens used for filtering, it is advanced beyond a pipe or tube of heading 7304, HTSUS.
You further suggest the proWRAP Well Screen be classified in subheading 8421.39, HTSUS, which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Other.” We disagree. As the proWRAP Well Screen is designed to filter sand from oil, gas or water it would not be classified as a device for filtering gas. Additionally, we find the proWRAP Well Screen to be very similar to the control screens found in ruling N236908 (dated January 28, 2013) in which Customs and Border Protection classified the merchandise in 8421.29, HTSUS.
Therefore, the applicable subheading for the proWRAP Well Screen will be 8421.29.0065, HTSUS, which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: Other: Other: Other: Other.” 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division