CLA-2-76:OT:RR:NC:N1:164
Eric Ziem
Rehblöcken 11a
Hamburg 22359
Germany
RE: The tariff classification of a composite overwrapped pressure vessel from Germany
Dear Mr. Ziem:
In your letter dated December 9, 2025, you requested a tariff classification ruling regarding a composite
overwrapped pressure vessel from Germany on behalf of your client, Blackwave GmbH. Technical
information was submitted with your request.
The item under consideration is described as a composite overwrapped pressure vessel (Type III COPV) used
for storing high-pressure gases (e.g., nitrogen, helium, etc.) in aerospace applications. Based on the submitted
information, the merchandise is a container consisting of an aluminum alloy liner overwrapped with carbon
fiber and epoxy. Additionally, it features two aluminum alloy fittings on opposing sides as ports for
connection to other objects.
Functionally, the aluminum alloy liner provides the main shape and internal structure of the container. It is
the structure and internal surface which contains compressed gases under high pressure. The carbon fiber and
epoxy overwrap provides additional structural integrity to the aluminum liner so that it can withstand high
internal pressure. As described, the vessel measures approximately 284 millimeters (mm) in length and
approximately 219 mm in outer diameter. In addition, it has a volume of approximately 5.18 liters, and a
maximum expected operating pressure of 400 bar.
In your ruling request you suggest classification of the composite overwrapped pressure vessel in
6815.13.0000, Harmonized Tariff Schedule of the United States (HTSUS), as other articles of carbon fibers.
However, the composite overwrapped pressure vessel is more specifically provided for elsewhere.
Classification in 6815.13.0000, HTSUS, is therefore precluded.
Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation
(GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the
headings and any relative section or chapter notes. Accordingly, if merchandise is specifically provided for in
the terms of a heading, it is classifiable there by operation of GRI 1.
The applicable subheading for the composite overwrapped pressure vessel (Type III COPV) will be
7613.00.0000, HTSUS, which provides for “Aluminum containers for compressed or liquefied gas.” The
general rate of duty will be 5 percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division