Mr. Felix Li
Schenker of Canada Limited
6555 Northwest Drive
Mississauga, Ontario Canada L4V 1K2

RE: The tariff classification of stainless steel hollow bars from China.

Dear Mr. Li:

In your letter dated August 1, 2012 you requested a tariff classification ruling on behalf of your client, Direct Alloys Inc. Descriptive literature and photographs were included with your submission.

The products to be imported are described as non-magnetic stainless steel bars used in oil and gas well drilling machinery. These “bars” are imported in 31 foot lengths in the following sizes: 4.75”, 6.5”, 6.75”, 8”, 8.25” and 9.5”. The manufacturing of the “bars” is a multi-step process comprised of three major operations: material processing, forging and machining which are performed in China.

Molded ingots are heated and then hammer forged into billets. Once the billets are formed, they undergo the following processes: rough machining/peeling, deep hole boring, machining the outer surface to the required size and roller burnishing the inner surface. The “bars” are then shipped to Canada and will be sold to U.S. based customers. After importation into the U.S., threaded connections (box and pin) as well as flex features are added to the “bars” which become drill collars and ready for use in the drilling machinery.

You suggest classification of the non-magnetic stainless steel “bars” in subheading 7222.11.0001, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other bars and rods of stainless steel, angles, shapes and sections of stainless steel, bars and rods, not further worked than hot-rolled, hot-drawn or extruded, of circular cross-section, electroslag or vacuum arc remelted. However, the subject “bars” do not have a uniform solid cross-section along their whole length, and therefore do not meet the Chapter 72, Note 1(m) definition of other bars and rods.

Consideration was also given to classify these products in heading 7228, HTSUS, which provides for other bars and rods of other alloy steel, angles, shapes and sections, of other alloy steel, hollow drill bars and rods, of alloy or non-alloy steel. The subject “bars” do not meet the dimensional requirements of hollow drill bars as defined in Chapter 72, Note 1(p). Hollow bars and rods of iron or steel not conforming to that definition are to be classified in heading 7304, HTSUS.

The applicable subheading for the non-magnetic stainless steel hollow bars will be 7304.49.0015, HTSUS, which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross section, of stainless steel, other, other, hollow bars. 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 World Wide Web at

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 Mary Ellen Laker at (646) 733-3020.


Thomas J. Russo
National Commodity Specialist Division