CLA-2-84:OT:RR:NC:1:102
Mr. George M. Keller
Customs Advisory Services, Inc.
1003 Virginia Ave.
Suite 200
Atlanta, GA 30354
RE: The tariff classification of a Modular Dual Bore Tree and Modular Spooltree of unspecified origin
Dear Mr. Keller:
In your letter dated April 22, 2008 you requested a tariff classification ruling on behalf of your client, Cameron International Corporation.
The items you plan to import are described as the Modular Dual Bore Tree and Modular Spooltree (“Christmas Trees”) used in an oil production system. The Christmas trees are comprised of an assembly of valves and also include actuators, chokes, control modules, tooling interfaces, etc. These Christmas trees are locked to the well head with mechanical connectors and connected to the drilling platform with lines.
The function of a Christmas tree is to prevent the release of oil or gas from an oil well into the environment and also to direct and control the flow of the well fluid. When the well is ready to produce oil or gas, valves are opened and the release of the well fluid is allowed through a pipeline leading to a refinery, a platform or a storage vessel.
You suggest the Christmas trees are correctly classified under subheading 8431.43.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of offshore oil and natural gas drilling and production platforms. However, we find the Christmas trees are not “parts” for tariff purposes, but rather composite articles having the essential character an appliance for controlling the flow of fluids. Such appliances are provided for in subheading 8481, HTSUS.
The applicable subheading for the Modular Dual Bore Tree and Modular Spooltree will be 8481.80.9050, HTSUS, which provides for other taps, cocks, valves and similar appliances. The rate of duty will be 2 percent ad valorem.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
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 Kenneth T. Brock at 646-733-3009.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division