Mr. Jaime Johnson Reyes
Yusen Logistics Americas Inc.
1300 Busse Road
Elk Grove, IL 60007

RE: The tariff classification of joint pipes from Japan, Thailand and China

Dear Mr. Reyes:

In your letter dated June 26, 2018, you requested a tariff classification ruling on behalf of your client, Usui International Corporation (UIC). A representative sample was included with your request and will be returned under separate cover.

The products to be imported are high-pressure joint pipes/tubes for use as fuel transfer lines for gasoline combustion engines. You state that these cold-drawn, seamless, cut-to-length stainless steel tubes have outside diameters ranging from 6 mm to 9 mm, inside diameters ranging from 3 mm to 5 mm and lengths ranging from 100 mm to 1,000 mm depending on engine specifications.

You suggest classification of the high-pressure joint pipes/tubes in heading 8409, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of diesel engines. This office disagrees with your proposed classification.

Classification of merchandise under the HTSUS is governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that the classification is determined first in accordance with the terms of the headings and any relative section and chapter notes. GRI 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description.

Furthermore, Additional U.S. Rule of Interpretation 1(c) states, "a provision for parts of an article covers products solely or principally used as a part of such articles but a provision for "parts" or "parts and accessories" shall not prevail over a specific provision for such part or accessory."

From the information submitted, it appears that the tubes under consideration are simply pipes that have not been made into a specific identifiable article. As a result, they are more specifically provided for as pipes in heading 7304, HTSUS, rather than parts of diesel engines of heading 8409, HTSUS.

The applicable subheading for the stainless steel high-pressure joint pipes/tubes will be 7304.41.3045, HTSUS, which provides for tube, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross section, of stainless steel, cold-drawn or cold-rolled (cold-reduced), of an external diameter of less than 19 mm, other, other. The duty rate is 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

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 9903.85.03 for aluminum. Products classified under HTSUS subheading 7304.41.3045 may be subject to additional duties or quota.  At the time of importation, you must report the Chapter 99 number applicable to your product classification in addition to the Chapter 72, 73 or 76 number 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 Mary Ellen Laker at [email protected]


Steven A. Mack
National Commodity Specialist Division