CLA-2-87:OT:RR:NC:N2:206
Bernardo Lara
Matthew J Leyendecker
10197 Crossroads Loop
Laredo, TX 78045
RE: The tariff classification of pipe assemblies from Mexico
Dear Mr. Lara:
In your letter dated December 15, 2025, you requested a tariff classification ruling on behalf of Katon Global
USA Inc.
The articles under consideration are pipe assemblies, which you also refer to as stainless-steel connector
sub-assemblies, Katon Part Number (KPN) 6008516, KPN 6008517, KPN 6008518, KPN 6008519, KPN
60036876, and KPN 60036879, which are used in motor vehicles. You state that the sub-assemblies are
engineered solely for integration into the GMT610 L8T Y-3x catalytic converter emissions aftertreatment
system. Their geometry, weldment configuration, internal diameters, and flow regulation characteristics are
designed specifically to manage, balance, and direct exhaust gas flow into three catalytic converter units for
purification and emissions control.
The sub-assemblies are made of stainless steel due to its high-temperature endurance, corrosion resistance,
and suitability for exhaust purification environments. Their technical functions include distributing exhaust
gases in precise volumes to catalyst substrates, maintaining defined pressure-drop requirements for system
performance, and supporting catalytic reaction efficiency.
KPN 60008516 and KPN 60008517 each consists of a flange, sensor boss, pipe, and bracket assembly (nut
and bracket). KPN 60008518 and KPN 60036876 each consists of a pipe and sensor boss. KPN 60008519
and KPN 60036879 each consists of two pipes, a sensor boss, and two stamped pieces.
In your letter, you suggest the applicable heading for the stainless-steel connector sub-assemblies to be 8421,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including
centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof.” We
disagree. Exhaust pipes, silencers, and catalytic converters are each distinct parts of the exhaust system with
their own unique jobs. The pipes transport gases, mufflers/silencers silence noise, and catalytic converters
clean emissions. Since each component has its own function, they would not be considered one single unit
but rather sequential components working together to manage noise, flow, and pollution before gases exit.
Accordingly, heading 8421 would be excluded from consideration.
The applicable subheading for the pipe assemblies KPN 6008516, KPN 6008517, KPN 6008518, KPN
6008519, KPN 60036876, and KPN 60036879 will be 8708.92.5000, HTSUS, which provides for “Parts and
accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Mufflers and
exhaust pipes; parts thereof: Mufflers and exhaust pipes: For other vehicles.” The general rate of duty will be
2.5 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.
Your inquiry does not provide enough information for us to give a classification ruling on Part Number KPN
60008520. Your request for a classification ruling should include the following information:
The exact chemistry of the outlet flange. Submit photos from various angles of the flanges in their
condition as imported into the United States.
Describe in detail, step-by-step, how the flanges are made. Include a manufacturing flow chart. What
connects to each end of the flange? Do the flanges connect pipe made of a single extruded compound
(i.e., metal or plastic) to pipe, pipe to hose made of many materials (i.e., rubber), hose to hose, or pipe
to an apparatus such as a valve? How is the connection made (i.e., screwing, bolting, welding, etc.)?
Please clarify. Is the flange made to an ASTM or other specification? If so, indicate the spec. What is
the function of the flange. Please provide a clearly labeled photo of the flange and the components to
which it is attached.
At the time of importation, are the flanges ready for their intended use? If not, what other
processing/manufacturing takes place in the U.S. to render them as finished goods? Submit a photo of
the flanges installed in their final application.
When this information is available, you may wish to consider resubmission of your request. We are returning
any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material
that we have returned to you.
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 Liana Alvarez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division