CLA-2-85:RR:NC:1:112 I81299

Mr. Scott L. Johnston
Givens and Associates, PLLC
950 Echo Lane
Houston, TX 77024-2788

RE: The tariff classification of an “On-Trak” measuring-while-drilling system and various components. The country of origin is not stated.

Dear Mr. Johnston:

In your letter dated April 22, 2002, on behalf of Baker Hughes INTEQ, you requested a tariff classification ruling.

As indicated by the submitted descriptive literature, the “On-Trak” measuring-while-drilling (MWD) system is designed to provide directional drilling guidance capabilities and formation evaluation data in the surface and subsurface drilling field. It enables a drilling operator to navigate a drill bit along a desired path based upon collected data and other parameters. The complete system is comprised of subassemblies (steel drill collar sections), a surface transponder, and a surface work cabin with workstations that control the subassemblies and process data.

The applicable subheading for the “On-Trak” MWD system will be 8543.89.9695, Harmonized Tariff Schedule of the United States (HTS), which provides for other electrical machines and apparatus, …, not specified or included elsewhere in Chapter 85, HTS. The general rate of duty will be 2.6 percent ad valorem.

You also inquire as to the tariff classification of the five major components of this system. These components are identified as the navigation subassembly, the UPUPH subassembly, the surface cabin, the navigation subassembly housing, and the UPUPU subassembly housing.

The applicable subheading for the navigation subassembly will be 9030.10.0000, HTS, which provides for instruments and apparatus for measuring or detecting ionizing radiations. The general rate of duty will be 1.6 percent ad valorem. The applicable subheading for the UPUPH subassembly, the surface cabin, the navigation subassembly housing, and the UPUPU subassembly housing will be 8543.90.8880, HTS, which provides for other electrical machines and apparatus, …, not specified or included elsewhere in Chapter 85, HTS; parts thereof: Parts: Other: Other: Other. The general rate of duty will be 2.6 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 David Curran at 646-733-3017.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division