CLA-2-84:OT:RR:NC:N1:106

Mr. Donald Simpson
Barthco International Inc. dba OHL-International
5101 South Broad St.
Philadelphia, PA 19112

RE: The tariff classification of oil drilling components from France.

Dear Mr. Simpson:

In your letter dated November 9, 2010, you requested a tariff classification ruling on behalf of your client, Thyssenkrupp Materials, NA, Inc. Literature and diagrams were submitted with your request.

Two components are under consideration. The first is a forged steel kelly. The kelly is a length of pipe which is designed and finished to be inserted through the rotary table of a drilling rig. The two variations of the kellys you describe are either square or hexagonal through their central length allowing for interaction with the rotary table. This characteristic allows them to rotate other lower components of the drill string under the power of the rotary table. The kelly is threaded at both ends in order to allow connections to be made.

The second component is a forged steel integral stabilizer. This tapered steel component is installed in the drill string in order to increase wear resistance between the drill string and the wall of the drill hole and provide directional stability.

The applicable subheading for the kellys and stabilizer will be 8431.43.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts suitable for use solely or principally with the machinery of headings 8425 to 8430: of machinery of heading…8430: parts for boring or sinking machinery of subheading 8430.41 or 8430.49: other, of oil and gas field machinery: other. 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 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 Mark Palasek at (646) 733-3013.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division