CLA-2-73:OT:RR:NC:N5:116
Kensie Sugama
Trade Pacific PLLC
700 Pennsylvania Ave. SE
Washington, DC 20003
RE: The tariff classification of alloy steel pipes from South Korea
Dear Ms. Sugama:
In your letter dated April 6, 2026, you requested a tariff classification ruling on behalf of your client,
Hyundai Steel Pipe America, Inc.
The products under consideration are identified as door impact “beams,” BEAM-FR DR REINF, Model
Number 76151. These hot-rolled electric resistance welded (ERW) alloy steel pipes are of a circular cross
section and are manufactured for use inside doors of specific vehicle models. You indicate that the pipes
measure 31.8 mm in outside diameter and 2.6 mm in wall thickness and have been coated for surface
treatment and rust prevention.
Consideration was given to classifying the beams in subheading 8708.29, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for parts of vehicle bodies, as you suggested. We disagree.
Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation
(GRI). GRI 1 provides that classification is determined according to the terms of the headings and any
relative section or chapter notes. However, when classifying parts of a machine/vehicle it is also necessary to
consider Additional U.S. Rule of Interpretation (AUSRI) 1(c), HTSUS, which reads “In the absence of
special language or context which otherwise requires … a provision for parts of an article covers products
solely or principally used as a part of such articles but a provision for “parts” or “parts and accessories” shall
not prevail over a specific provision for such part or accessory.”
The next step is to determine if a specific provision exists for the beams in question. Heading 7306, HTSUS,
provides for tubes, pipes and hollow profiles of iron or steel. In the condition as imported, the beams are
straight length tubes that are not identifiable as motor vehicle components. The end use and final application
of the beams do not negate this concept. As a result, classification of the beams in subheading 8708.29,
HTSUS, is precluded.
To support classification in subheading 8708.29, HTSUS, you cite rulings HQ 084670, dated September 22,
1989, HQ 956790, dated October 28, 1994, and HQ 966623, dated June 21, 2004.
In Ruling HQ 084670, the straight-cut lengths of mechanical tubing were classified in 7304, HTSUS, which
are similar to the beams in question. It was the contour-cut length tubing that was classified in heading 8708,
HTSUS.
In Ruling HQ 956790, the tubing was tapered to accept a mounted wheel bearing on one end and an axle
carrier on the other end, and one end of each tube was tapered to make it smaller than the other end. As such,
they were recognizable as automotive components and were classified as such in heading 8708, HTSUS.
In Ruling HQ 966623, the straight-cut tubing was classified in heading 7306, HTSUS. It stated that “[u]nlike
the pipes in HQ 956790, the instant pipes are simple straight lengths of pipe.” The beams at issue resemble
the pipes described in this ruling.
The applicable subheading for the alloy steel pipes will be 7306.50.5050, 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 other alloy steel: having a wall thickness of 1.65 mm or
more: other: other, with an outside diameter not exceeding 114.3 mm. The rate of duty will be free.
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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Neil M. Cohen at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division