CLA-2-73:OT:RR:NC:N5:116
William C. Faulhaber
Integer Holdings Corporation
5830 Granite Parkway, Suite 1150
Plano, Texas 75024
RE: The tariff classification of stainless steel tubes from France
Dear Mr. Faulhaber:
In your letter dated July 21, 2026, you requested a tariff classification ruling.
The products to be imported are Type 304L stainless steel tubes that are used to create guidewires, pull rings,
and valve replacement devices for medical applications (i.e. catheter, valve replacement, etc.). The tubes are
imported in varying lengths and dimensions and are made into components of a catheter-based delivery
system. You indicated that the stainless steel tubes have a wall thickness of less than 1.65 mm. The smaller
outside diameter (OD) tubing is made from 304L SS strip. A specialized machine simultaneously forms and
welds the unspooled 304L stainless steel strip into finished tubing. This smaller OD welded tubing is
cold-drawn through multiple passes to create the final tubing size. The larger OD seamless tubing is made
from a 304L SS bar. It is gun-drilled to a specific size, then cold-drawn/reduced to specified final
dimensions.
You suggest classification of the stainless steel tubes under subheading 9018, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for provides for catheters, cannulae and the like, and parts and
accessories thereof. We disagree. As you stated, at the time of importation, all the listed tubes are “imported
to be further worked.” In their imported condition, these tubes are merely tubes and not parts or accessories
of any specific medical instruments. Accordingly, the stainless steel tubes, in their imported condition, are
not classified under heading 9018.
The applicable subheading for the smaller OD stainless steel tubes will be 7306.40.1015, 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
less than 1.65 mm, containing more than 0.5 percent by weight of nickel, other. The rate of duty will be free.
The applicable subheading for the larger OD seamless tubing will be 7304.41.3045, HTSUS, which provides
for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel: other, of circular cross
section, of stainless steel: cold-drawn or cold-rolled (cold-reduced): Of an external diameter of less than 19
mm: other: other. 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