CLA-2-73:OT:RR:NC:N5:116
Aiswarya S. Baiju
RVL Metals Inc.
1448 Yorkshire Drive
Streamwood, Illinois 60107
RE: The tariff classification of stainless steel pipes from India
Dear Mr. Baiju:
In your letter dated January 2, 2026, you requested a tariff classification ruling, a marking determination, and
a country of origin determination.
The products to be imported are welded stainless steel pipes with a circular cross section. According to your
submission, all of the pipes in question are welded, cold-drawn, polished and have a wall thickness of 1.65
mm or more. Based on the mill test certificates provided, all pipes contain more than 0.5%, but less than 24%
by weight of nickel.
The applicable subheading for all of the pipes will be 7306.40.5040, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for other tubes, pipes and hollow profiles (for example, open seamed
or welded, riveted or similarly closed), of iron or steel: other, welded, of circular cross section, of stainless
steel: having a wall thickness of 1.65 mm or more: other: other, cold-drawn or cold-rolled (cold-reduced):
containing more than 0.5 percent but less than 24 percent by weight of nickel. The rate of duty will be free.
Although you have also requested a country of origin determination, you have indicated that “[t]he country of
origin for all subject stainless steel pipes is India. All manufacturing operations, including forming, welding,
cold-finishing, heat treatment (where applicable), testing, and inspection are performed in India.” As per your
indication, the country of origin for marking purposes is India.
You have also requested a determination on whether the proposed marking seen in the photos provided is
sufficient. The marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that
unless excepted, every article of foreign origin imported into the U.S. shall be marked in a conspicuous place
as legibly, and permanently as the nature of the article (or container) will permit, in such a manner as to
indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article.
Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements
and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates
that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain.
19 U.S.C. 1304(c)(1), requires that all pipe (iron, steel, stainless steel), tube and pipe fittings (steel, stainless
steel, chrome-moly steel or cast or malleable iron) shall be marked to indicate the proper country of origin by
one of five methods: 1) die stamping, 2) cast-in-mold lettering, 3) etching, 4) engraving, or 5) continuous
paint stenciling.
As the pipes will be “legibly, indelibly, and permanently marked at the time of importation into the United
States by continuous paint stenciling with” “Made in India” or “Product of India”, the manufacturer’s name
or trademark, the ASTM specification, and the grade and size details as indicated in the photo provided, we
find that the proposed marking is sufficient under the marking statute referenced above.
Please be advised that the stainless steel pipes from India may be subject to antidumping duties and/or
countervailing duties (AD/CVD). 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.
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.
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/current.
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 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, contact
National Import Specialist Angelia Amerson at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division