CLA-2-84:S:N:N1:102 876827

Ms. Linda Campanian
Milne & Craighead Customs Brokers
200 International Boulevard
P.O. Box 2
Sweetgrass, MT 59484

RE: The tariff classification of a downhole mud motor from Canada

Dear Ms. Campanian:

In your letter dated July 24, 1992, on behalf of your client, Drilmaster, you requested a tariff classification ruling.

The item involved in this ruling request is a directionally controllable downhole mud motor for use in such fields as oil exploration. The entire motor consists of several sections: a submotor section; a dump valve section; a power section; a connecting rod assembly; and a bearing assembly. The specifically designed motor in the Drilmaster mud motor is a multi-stage device which makes up approximately half the length of the tool. It consists of only two parts, a rotor and a stator, both of which you state are products of the United States.

The stator tube forms the outer body of the motor assembly. This tube is lined with a rubber-like compound (buna N) that resists abrasion and damage from hydrocarbons. The cavity of the stator is spiral shaped in length and can have any one of several shapes in cross section. Fluid (mud) is pumped down the length of the string where it eventually enters the rotor/stator section under pressure. This pressurized mud causes the rotor to turn, thereby powering the drill bit.

The applicable subheading for the downhole mud motor will be 8412.29.8060, Harmonized Tariff Schedule of the United States (HTS), which provides for other hydraulic power engines and motors; unlimited rotary acting. The duty rate will be 3.4 percent ad valorem.

Goods classifiable under subheading 8412.29.8060, HTS, which have originated in the territory of Canada, will be entitled to a free rate of duty under the United States-Canada Free Trade Agreement (FTA) upon compliance with all applicable regulations.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport