CLA-2-84:OT:RR:NC:N1:102
9903.01.24, 9903.88.01, 9903.88.03
Connor Beck
J&W Services and Equipment Company
3510 TX-158
Midland, TX 79705
RE: The tariff classification of items used in the production of oil and gas from China
Dear Mr. Beck:
In your letter dated February 27, 2025, you requested a tariff classification ruling. The merchandise under
consideration are items used to maintain pressure and containment within a wellbore. The four items will be
constructed of alloy steel or stainless steel material.
The first item is referred to as a casing head, item number WH*CH-0101. The casing head is an adapter
designed to be installed between a casing string and a blowout preventer stack or a wellhead.
The second item is referred to as a cross, item number T1003. The cross, which consists of three or more
connections, is used in a “Christmas Tree” (a specialized valve assembly).
The third item is referred to as a casing hanger, item number WH*MBS-0101. The casing hanger supports
the casing string when in a wellbore. The casing hanger positions a drilling string and is a sealing device.
The fourth item is referred to as a flange, item number WH*IL-0202. The flanges can be constructed of
stainless steel or alloy steel and are used to connect pipes in order to control the flow of oil or gas coming out
of a well.
The applicable subheading for the casing head (WH*CH-0101) will be 7326.90.8688, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for other articles of iron or steel: other…other. The
general rate of duty will be 2.9 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7326.90.8688, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 7326.90.8688, HTSUS, listed above.
The applicable subheading for the cross (T1003) will be 8481.90.9081, 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: Parts: Other: Other: Other:
Steel forgings. The general rate of duty is Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8481.90.9081, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01,
in addition to subheading 8481.90.9081, HTSUS, listed above.
The applicable subheading for the casing hanger (WH*MBS-0101) will be 8479.89.9550, HTSUS, which
provides for Machines and mechanical appliances having individual functions, not specified or included
elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Oil and gas
field wireline and downhole equipment. The general rate of duty will be 2.5 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8479.89.9550, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 8479.89.9550, HTSUS, listed above.
The applicable subheading for the stainless steel flanges (WH*IL-0202) will be 7307.21.5000, which
provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other, of stainless
steel: flanges: other. The general rate of duty will be 5.6 percent ad valorem.
The applicable subheading for the alloy steel flanges (WH*IL-0202) will be 7307.99.5060, HTSUS, which
provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other: other:
other: of alloy steel (except stainless steel). The general rate of duty will be 4.3 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 7307.21.5000 and 7307.99.5060, HTSUS, unless specifically excluded, are subject to an
additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99
subheading, i.e., 9903.88.03, in addition to subheading 7307.21.5000 or 7307.99.5060, HTSUS, listed above.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 7326.90.8688, 7307.21.5000, 7307.99.5060, 8481.90.9081 or 8479.89.9550 HTSUS, listed
above.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e., 9903.81.90, in addition to subheading 7326.90.8688,
7307.21.5000, or 7307.99.5060, HTSUS. Derivative iron or steel products processed in another country from
steel articles melted and poured in the United States, provided for in heading 9903.81.92, are not subject to
the additional ad valorem duties. Please note that derivative steel products admitted to a U.S. foreign trade
zone under ?privileged foreign status? before March 12, 2025, and entered for consumption on or after March
12, 2025, may be subject to additional duties under heading 9903.81.93, HTSUS.
Please be advised that the stainless steel flanges may be subject to antidumping duties and/or countervailing
duties. Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and
Compliance office in the International Trade Administration of the Department of Commerce (ITA) and are
separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). General
information regarding the ITA and AD/CVD can be found at
https://www.trade.gov/us-antidumping-and-countervailing-duties. The ITA?s ?Guide on How to File for an
Antidumping/Countervailing Duty Scope Ruling Request? is available at
https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf.
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 https://hts.usitc.gov/.
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 and Border Protection
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, please contact
National Import Specialist Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division