CLA-2-90:OT:RR:NC:N1:105
Hugo Malagutti Controle Mesure Systemes 6 rue des Loches Sevrey 71100 France RE: The tariff classification of non-destructive testing equipment from France Dear Mr. Malagutti: In your letter dated October 1, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The items under consideration are described as non-destructive testing (NDT) equipment, which are devices designed for the inspection of metallic tubes, bars, and wires during or after the manufacturing process. The systems use physical measurement principles such as Eddy Current and Ultrasonic testing to detect surface and internal defects, inclusions, or dimensional deviations. The Eddy Current Method includes inspection using an Eddy Current encircling or segment coil to detect short and transverse defects, as well as open welds. This method allows for the high-speed inspection of magnetic or non-magnetic products with various profiles. These coils are connected to the Eddy Current generators. The user interface of the software enables the operator to adjust Eddy Current settings, display signals, and set alarm thresholds. The Ultrasonic Method uses a full range of Ultrasonic rotating heads. They handle tubes with diameters ranging from 4 to 250mm (0.157 to 10 inches). The Ultrasonic transducers are submerged in water while rotating at very high speed around the product as it passes through the head. Internal and external defects, including longitudinal, transverse, and oblique flaws, are detected by the multi-channel systems. The inspected defect size can be as small as 1.58 by 0.1 by 0.025mm (0.6 by 0.004 by 0.001inch). A RotoUTscan connected to the Ultrasonic instrument, MultiUTscan, can also perform highly accurate dimensional measurements, including wall thickness (WT), inner diameter (ID), outer diameter (OD), eccentricity, and ovalization, with an accuracy of plus or minus 3m.
A typical system would include test heads, electronic units, and auxiliary equipment. The test heads are equipped with encircling coils (Eddy Current) or ultrasonic probes that are positioned around or in contact with the material under test. The electronic units are used for signal generation, acquisition, and processing. These devices analyze the response of the material to induced electromagnetic fields or ultrasonic waves. Finally, the auxiliary equipment includes devices such as electrical cabinets and mechanical supports for in-line or off-line installation. The equipment is used in industrial environments by manufacturers of tubes, pipes, and bars to ensure product quality, compliance with standards, and detection of defects without altering or damaging the tested material. The systems do not perform destructive testing, material removal, or machining. They are exclusively designed for measurement and inspection purposes. As you suggest in your letter, the applicable subheading for the non-destructive testing equipment will be 9031.80.8085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” The general rate of duty will be free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 9031.80.8085, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Jason Christie at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division