CLA-2-73:OT:RR:NC:1:117
8536.90.4000
Mr. Reid Shepley
Boshart Industries
P.O. Box 310
25 Whaley Ave.
Milverton, Ontario N0K 1M0
RE: The tariff classification of “Pump Package” items from various countries.
Dear Mr. Shepley:
In your letter dated March 29, 2011 you requested a tariff classification ruling. Representative samples were submitted with your request and will be returned to you.
The product to be imported is described as a “Pump Package” used in the installation/repair of water pump systems in a drilled water well. This “package” will consist of the following items:
Item No. P-100-SS, 304 S.S. Pitless Adapter, is a cast stainless steel fitting. Described as a two-piece fitting, the item also contains a rubber gasket and nut. This T-shaped assembly has three threaded openings. One part of the fitting is installed into the side of the well casing while the other half connects the pipe coming up from the submersible pump.
Item No. PW2-10, Pipe Wrap, is an adhesive backed PVC tape. Measuring 2 inches (5.08 cm) in width, this wrap is imported in rolls of 100 feet and can be used on all types of pipes and fittings.
Item No. SSC8720, # 20 301 S.S. Hose Clamp, is a stainless steel clamp used to fasten plastic and rubber hoses to pipe fittings.
Item No. WTCC-6-CI, Watertight Cast Iron Well Cap, is used to close off the top of the well casing providing a water tight seal between the well casing and the retainer ring. It also allows access to the electrical cable for the operation of the submersible pump.
Item No. WG-6, Snap-In Cable Guard, is a plastic shield used to keep the power cable from abrading against the well casing.
Item No. TA-48-Green, Torque Arrestor, is a flexible plastic cover that fits around a submersible pump acting as a type of bumper. Imported with clamps to hold the two halves of the arrestor together, this set is packaged together for retail sale.
Item Nos. SSMA-100 & SSMA-125-100, 304 S.S. Male Insert Adapters are stainless steel fittings used to connect steel pipe to plastic hose. Although the SSMA-125 is larger, each of these adapters has one threaded end, one barbed end and are used in conjunction with a hose clamp to secure the hose to the adapter.
Item No. HSKC-4, Wire Heat Shrink Kit, consists of four #14-#10 AWG (American Wire Gauge) aluminum in-line crimp terminal butt connectors and four plastic adhesive lined heat shrink tube insulators. The butt connectors and tube insulators are imported packaged together within a sealed clear plastic bag with installation instructions printed on the back. They are designed to make a solder-less splice between two conductors end to end. Once the termination is complete, the plastic insulator tubes are slid over the splice and heated to form a protective barrier over the electrical connection.
The applicable subheading for the pitless adapters will be 7307.19.9060, Harmonized Tariff Schedule of the United States (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 general rate of duty will be 6.2 percent ad valorem.
The applicable subheading for the pipe wrap will be 3919.10.2055, Harmonized Tariff Schedule of the United States (HTSUS), which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, whether or not in rolls, in rolls of a width not exceeding 20 cm, other, other, other. The general rate of duty will be 5.8 percent ad valorem.
You indicated in your letter that CBP classified cast iron well caps in NY ruling G86433 under subheading 7325.10.0080, HTSUS. However, our office does not have any background/specific product information on the subject well caps in NY G86433.
In order to provide a classification for the WTCC-6—C1 Watertight Cast Iron Well Cap, our office must first determine whether the imported item has been advanced beyond a casting. As to what processes are sufficient to advance an item beyond a casting is addressed in HQ 963283 dated May 11, 2000, which states “Customs longstanding position on the issue of advancements to castings is that the casting process is considered complete when, after the casting solidifies and cools, surface imperfections are removed by blast cleaning, chipping, burning or combinations of these processes. Certain independent and additional processes not merely incidental to the general foundry work are considered to advance an article beyond casting.” This matter was addressed in NY G81782 dated September 25, 2000, concerning a steel casting. In that ruling it was determined that “once the steel casting is further processed…by machine-lathing to specific size and drilling holes, it has been advanced beyond the definition of a cast article.” Based on the product information available to our office, the subject well caps have been advanced beyond the definition of a cast article and would be classifiable in heading 7326, HTSUS.
The applicable subheading for the hose clamps and well caps will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.
The applicable subheading for the cable guard and torque arrestor will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics and articles of other materials of headings 3901 to 3914, other, other, other. The general rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the male insert adapters will be 7307.29.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, of stainless steel, other, other. The general rate of duty will be 5 percent ad valorem.
The applicable subheading for the wire heat shrink kit will be 8536.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches, relays, fuses, surge suppressors, plugs, sockets, lamp-holders and other connectors, junction boxes), for a voltage not exceeding 1,000 V; connectors for optical fibers, optical fiber bundles or cables, other apparatus, terminals, electrical splices and electrical couplings; wafer probers . The general rate of duty will be free.
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 Mary Ellen Laker at (646) 733-3020.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division