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