Mr. Keith Larson
Venture Global LNG, Inc.
1001 19th Street North
Arlington, Virginia 22209

RE:      The tariff classification of nickel alloy pipes from Germany  

Dear Mr. Larson:

In your letter dated September 26, 2023, you requested a tariff classification ruling.

The products to be imported are identified as 36% Nickel Alloy (Invar®) pipes for use in pipe-in-pipe (PIP) assemblies in a liquefied natural gas (LNG) facility. According to your submission, these cold-rolled, pickled, longitudinally welded pipes will be imported in four sizes:

                           1) 28.063” (712.8 mm) outside diameter (OD) with a .346” (8.7 mm) wall thickness (WT);                            2) 34.063” (865.2 mm) OD with a .386” (9.8 mm) WT;                            3) 40.076” (1017.9 mm) OD with a .720” (18.2 mm) WT; and                            4) 40.076” (1017.9 mm) OD with a .551” (13.9 mm) WT  

You indicate that the 40” OD pipe will also have an anti-corrosion coating. After importation, the 28” OD and 34” OD pipes are cut-to-length, wrapped with Izoflex insulation, and inserted into the 40” OD pipe to make the final PIP assembly.

The applicable subheading for the nickel alloy pipes, whether coated or uncoated, will be 7305.31.6090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other tubes and pipes (for example, welded, riveted or similarly closed), having circular cross sections, the external diameter of which exceeds 406.4 mm, of iron or steel: other, welded, longitudinally welded: other: of alloy steel, other. The rate of duty will be free.

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 subheading 7305.31.6090, 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 HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. 

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

The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.

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].


Steven A. Mack
National Commodity Specialist Division