CLA-2-74:RR:NC:N1:117 M87518

Mr. Steven Mahal
Ram International
1650 Carmen Drive
Elk Grove, IL 60007

RE: The tariff classification of threaded brass elbows from China.

Dear Mr. Mahal:

In your letter, dated October 13, 2006, on behalf of your client, Barco USA, A Division of Marison Industries, Cary, IL, you requested a tariff classification ruling.

The merchandise is comprised of threaded brass elbows in styles A and B, of various sizes. These threaded elbows have been specially made for incorporation into the E-75RS rotary joint. The E-75RS rotary joint is a device used in the conveyance of water or steam. The brass elbow constitutes the stationary supply pipe end of the E-75RS rotary joint. Applications for this product include couplings to chilling rolls for printing and steel production machinery.

The applicable subheading for the threaded brass elbows will be 7412.20.0035, Harmonized Tariff Schedule of the United States (HTSUS), which provides for copper tube or pipe fitting (for example couplings, elbows, sleeves), of copper alloys, other, of copper-zinc base alloys, (brass), threaded, other. The rate of duty will be 3%.

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 World Wide Web at

In your correspondence you suggest that these products should be classifiable under 7412.20.0085. However, that subheading provides for copper tube or pipe fittings of copper alloys other than copper-zinc base alloys (brass). 7412.20.0035, HTSUS, which provides for copper tube or pipe fittings of copper alloys that are of copper-zinc base alloys (brass), is a more specific provision.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Gloria Stingone at 646-733-3020.


Robert B. Swierupski
National Commodity
Specialist Division