CLA-2-73:RR:NC:1:117 D89819

Mr. Jeffrey L. Snyder
Sonnenschein Nath & Rosenthal
1301 K Street N.W.
Suite 600, East Tower
Washington, D.C. 20005

RE: The tariff classification of steel tubing from Germany.

Dear Mr. Snyder:

In your letter dated March 25, 1999 on behalf of Chicago P.P.L., Inc., you requested a tariff classification ruling. Representative samples were submitted with your ruling request.

The product to be imported is seamless, cold-drawn carbon and alloy steel precision tubing used in mechanical and high pressure applications. A typical grade of carbon steel is 1010, and a typical grade of alloy steel is 4130. The tubing, produced by Poppe & Potthoff GMBH & Co. (P & P), is circular in cross section. Most of the tubing (approximately 95%) will have outside diameters of less than 1/2 inch. Wall thicknesses and lengths will vary. Applications for the P & P tubing include diesel injection lines, support rods for mechanical drilling instruments, and shafts for airguns/rifles.

The applicable subheading for the seamless, cold-drawn carbon steel precision tubing will be 7304.31.60, Harmonized Tariff Schedule of the United States (HTS), which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross section, of iron or nonalloy steel, cold-drawn or cold-rolled (cold-reduced), other. The rate of duty will be 4 percent ad valorem.

The applicable subheading for the seamless, cold-drawn alloy steel precision tubing will be 7304.51.50, HTS, which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross section, of other alloy steel, cold-drawn or cold-rolled(cold-reduced), other. The rate of duty will be 3.8 percent ad valorem. 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 Paula Ilardi at 212-637-7016.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division