CLA-2-39:OT:RR:NC:SP:221
Mr. Jeffrey Meeks
Meeks, Sheppard, Leo & Pillsbury
330 Madison Avenue, 39th Floor
New York, NY 10017
RE: The tariff classification of couplings, valves and connections and fittings.
Dear Mr. Meeks:
In your letter dated August 14, 2008, on behalf of Colder Products Company, you requested a tariff classification ruling.
Samples were provided with your letter. All the samples are said to be for use with flexible tubing, and serve as components for the flow of liquid or gas through the line. Samples 6 and 6A, the Saniquik Series Connection SQCC221212M MPC Series and SQCX222424 MPX Series, are stainless steel sanitary termination devices to be incorporated with stainless steel processing equipment allowing easy connection to a single use bag or tube sets of plastic materials. The Sanitary Series Sanitary Couplings (MPC3301239 and MPX3301239) are plastic connections with plastic thumb latches. They do not contain a valve but allow for the straight flow of liquids and gases. They are designed to connect to the Saniquik Series Connections. The IdentiQuik PLC Series Smart Coupling with RFID (Sample 5) is a coupling reader with a shutoff valve. Samples 7 and 8 are Steam-Thru Connections-STC2020000 Polysulfone. These are three port connections to biopharmaceutical equipment, disposable bags and tubing assemblies. Sample 8 contains a valve. Sample 7 is said to contain a valve, but the sample does not appear to have a valve.
The applicable subheading for the Saniquik Series Stainless Connection devices (Samples 6 and 6A) will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent.
The applicable subheading for Sample 5, the IdentiQuik PLC Series Smart Coupling with RFID, will be 8481.80.90, HTSUS, which provides for taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves: parts thereof…other appliances, other. The rate of duty will be 2 percent ad valorem.
The applicable subheading for Sample 8, the Steam-Thru Connections – STC2020000 Polysulfone, will be 8481.80.5090, HTSUS, which provides for taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves: parts thereof…other appliances, hand operated. The rate of duty will be 3 percent ad valorem.
We cannot provide a classification for Sample 7, the Steam-Thru Connection, or for the Sanitary Series Sanitary Couplings. The Steam-Thru Connection is said to have a valve, but the sample does not appear to contain a valve. If you wish a binding ruling for this item, please provide a detailed explanation of how this item works, as well as descriptive literature complete with pictures. You suggest classification for the Sanitary Series Sanitary Couplings as tube fittings, but have submitted no information indicating that they connect to any tubes. If you wish a binding ruling on the Sanitary Couplings plastic connections, provide detailed information or descriptive literature showing how these devices attach to a tube.
You did not state the country of origin in your letter. The rates of duty provided above are those rates applicable to the goods when they are made in a country with which the United States has Normal Trade Relations. 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 http://www.usitc.gov/tata/hts/.
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 Joan Mazzola at (646) 733-3023.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division