CLA-2-76:OT:RR:NC:N1:113
Christophe Maggioli
Zentra USA Corp
PO Box 140970
Coral Gables, FL 33114
RE: The tariff classification of gas storage cylinders from Spain
Dear Mr. Maggioli:
In your letter dated July 21, 2026, you requested a tariff classification ruling. Technical information was
submitted with your request.
The products at issue are gas storage cylinders including product numbers: B50.WP200.00,
B20.WP200.00.0000, B13.WP200.00.0000, B45.WP300.01.0000, B30.WP300.01.0000,
B18.WP300.01.0000, and B12.WP300.01.0000. These cylinders are described as Type III composite
overwrapped pressure vessels (COPV) designed to store high-pressure gases. Each cylinder consists of an
internal aluminum liner with an overwrap of composite carbon fiber and epoxy resin. Overall, these cylinders
have an outer diameter of 265 millimeters (mm) with lengths that range from 515 mm to 1545 mm. The
operational working pressure for B50.WP200.00, B20.WP200.00.0000 and B13.WP200.00.0000 is 200 bar,
and the working pressure for B45.WP300.01.0000, B30.WP300.01.0000, B18.WP300.01.0000 and
B12.WP300.01.0000 is 300 bar.
In your request you suggest classification of the cylinders should be in heading 6815, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Articles of stone or of other mineral substances
(including carbon fibers, articles of carbon fibers and articles of peat), not elsewhere specified or included.”
However, the cylinders are more specifically provided for elsewhere. Classification in 6815, 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 by operation of GRI 1. There are more specific headings that cover
“containers for compressed or liquefied gas.” Functionally, the aluminum liner provides the main shape and
internal structure of the cylinders and contains compressed gases under high pressure. Accordingly, the gas
storage cylinders are classifiable in heading 7613, HTSUS.
The applicable subheading for the gas storages cylinders 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 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 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 Matthew Gay at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division