CLA-2-73:OT:RR:NC:N5:116
Kyle O’Connor
Dominion Customs Consultants
1595 16th Avenue, Suite 202
Richmond Hill, Canada L4B 3N9
RE: The tariff classification and country of origin of an Industrial Pitless unit
Dear Mr. O’Connor:
In your letter dated July 23, 2026, you requested a tariff classification and a country of origin ruling for the
purposes of the applicability of trade remedies on behalf of your client, Boshart Industries LLC.
The product under consideration is identified as a spool type Industrial Pitless unit made of type 304 cast
stainless steel. This composite good is comprised of a well cap, upper barrel, lift pipe assembly, discharge
housing, and spool and will be imported in an assembled condition. The discharge housing and spool form a
tee type pipe fitting (pitless adapter) with three threaded openings that attach to pipe: drop pipe, upper barrel,
and service line. You indicate that the discharge housing and spool creates a 90º elbow that directs the flow
of water from the submersible pump into the service line below the frost line to prevent freezing. An upper
barrel extends the well casing to the surface for easy access to the well, attaches to the well cap, and provides
an additional 2 ft. above ground section to prevent surface water from contaminating the well. You state that
the Industrial Pitless unit does not contain any mechanical features at the time of importation.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, composite
goods consisting of different materials or made up of different components, and goods put up in sets for retail
sale shall be classified as if they consisted of the material or component which gives them their essential
character, which may be determined by the nature of the material or component, its bulk, quantity, weight or
value, or by the role of a constituent material in relation to the use of the article. This office finds that the
essential character of the Industrial Pitless unit is imparted by the discharge housing and spool (pitless
adapter) which forms a two-piece elbow that directs the flow of water throughout the unit.
You suggest classification of the Industrial Pitless unit under subheading 7307.29.0090, HTSUS, which
provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other, of stainless
steel: other: other. We disagree. The subject fitting is made from cast stainless steel. Cast fittings are more
specifically provided for elsewhere in heading 7307, HTSUS.
The applicable subheading for the Industrial Pitless unit will be 7307.19.9060, HTSUS, which provides for
tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: cast fittings: other: other:
other: other: threaded. The rate of duty will be 6.2 percent ad valorem.
When determining the country of origin for purposes of applying current trade remedies under Section 232,
Section 301, and other duties, the substantial transformation analysis is applicable. See, e.g., Headquarters
Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantial
transformation will occur is whether an article emerges from a process with a new name, character, or use
different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States,
681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand
Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
According to your submission, the discharge housing and spool (pitless adapter) of Chinese origin and well
cap are exported to Canada and joined/assembled with the upper barrel, the lift pipe, down hooks, and weld
nipples that are made in Canada from raw materials sourced from various countries to produce the Industrial
Pitless unit.
Based on the information provided, in our view the operations performed in Canada are neither complex nor
do they result in a substantial transformation. The pitless adapter and well cap are assembled with the other
parts that are already made in Canada. The final assembly operations that are performed in Canada include
the following: threading the lower housing onto the upper barrel, threading the lower nipple into the lower
housing, threading the lift pipe into the spool, installing O-rings onto the spool, installing spool/lift assembly
into upper barrel/lower housing assembly, installing and tighten hold down hooks, assembling the well cap,
and installing the well cap on the upper barrel. The components do not lose their separate identities when
assembled into the finished product. It is the opinion of this office that the pitless adapter of Chinese origin
provides the essence of the finished Industrial Pitless unit as it directs the water flow up the drop pipe and out
of the discharge pipe to the service line. As such, we find that the country of origin of the Industrial Pitless
unit for the purposes of the applicability of a trade program or a trade remedy will be China.
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 Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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