CLA-2-74:OT:RR:NC:N5:116
Mr. Brian Scott
ETG Trading Inc
1261 Post Rd, Suite 102
Fairfield, CT 06824
RE: The tariff classification of seamless copper tubes from Vietnam
Dear Mr. Scott:
In your letter dated March 4, 2025, you requested a tariff classification ruling.
The products to be imported are described as seamless alloy tubes meeting ASTM B75, 251, 743, the
standard specification for Copper Alloy (UNS C14435). According to your submission, the subject tubes will
be imported in both straight lengths and in coils with outside diameters ranging from 4.78 mm – 22.23 mm
and wall thicknesses ranging from 0.34 mm – 1.20 mm. The tubes consist of 99.5% copper and 0.3% - 0.5%
tin and are designed for high pressure and refrigerant heat transfer applications.
You suggest that this product may be classifiable in 7411.29.1000, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for copper tubes and pipes, of copper alloys, other, seamless. We disagree.
Based on the chemical composition noted above, the copper tubes meet the Chapter 74, Note 1(a) definition
of refined copper. Therefore, this merchandise is precluded from classification as a copper alloy.
The applicable subheading for the copper tubes imported in straight lengths and for the copper tubes
imported in coils having an outside diameter less than 6 mm and/or an outside diameter more than 16 mm
will be 7411.10.1090, HTSUS, which provides for copper tubes and pipes, of refined copper, seamless, other.
The rate of duty will be 1.5 percent ad valorem.
The applicable subheading for the copper tubes imported in coils and having an outside diameter of 6 mm or
more but not more than 16 mm will be 7411.10.1030, HTSUS, which provides for copper tubes and pipes, of
refined copper, seamless, having an outside diameter of 6 mm or more but not exceeding 16 mm, in coils on
spools. The rate of duty will be 1.5 percent ad valorem.
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 Angelia Amerson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division