CLA-2-81:RR:NC:1:118 J80536
Ms. Shelley Vybiral
Snap-tite Inc.
8325 Hessinger Dr.
Erie, PA 16509
RE: The tariff classification of tubing and nipples.
Dear Ms. Vybiral:
In your letter dated January 24, 2003, you requested a tariff classification ruling.
You have described your items as follows:
Titanium Grade 2 tubing – Low, medium and high pressure, seamless tube ranging in size from 1.59 mm to 25.4 mm diameters and lengths exceeding 12”. It is designed to handle pressures up to 150,000psi and used in the high-pressure fluid handling industry, with applications in the chemical, petrochemical, research and oil and gas industries.
Nickel 200 tubing - Low, medium and high pressure, seamless tube ranging in size from 1.59 mm to 25.4 mm in diameter and lengths exceeding 12”. It is designed to handle pressures up to 150,000psi and used in the high-pressure fluid handling industry with applications in the chemical, petrochemical, research and oil and gas industries. The chemical composition provided for Nickel 200 was Ni with cobalt-min 99%, Mn (manganese) max 0.35% and Si (silicon) 0.35% max.
Hastelloy C276 tubing - Low, medium and high pressure seamless tubing ranging in size from 1.59 mm to 25.4 mm in diameter and lengths exceeding 12”, designed to handle pressures up to 150,000psi.
Titanium Grade 2 nipple – This is a coned and threaded piece of the above tubing used to interconnect valves and fittings and are up to 12” in length. They come in medium or high pressure, for use up to 150,000psi.
Nickel 200 nipple - This is a coned and threaded piece of the above tubing used to interconnect valves and fittings and are up to 12” in length; comes in medium or high pressure, for use up to 150,000psi.
The applicable subheading for the Titanium Grade 2 tubing will be 8108.90.6060, Harmonized Tariff Schedule of the United States (HTS), which provides for titanium and articles thereof, including waste and scrap: other: other: tubes and pipes.
The applicable subheading for the Nickel 200 tubing will be 7507.12.0000, HTS, which provides for nickel tubes, pipes and tube or pipe fittings (for example, couplings, elbows, sleeves): tubes and pipes: of nickel alloys. The chemical composition provided for Nickel 200 was Ni with cobalt-min 99%; Mn (manganese) max 0.35% and Si (silicon) 0.35% max. If elements (other than iron, oxygen or cobalt) exceeds 0.3% each, then the definition for nickel alloys (Subheading Note 1(b)(ii)) is met. Accordingly Nickel 200 tubing meets the definition for nickel alloy.
The applicable subheading for Hastelloy C276 tubing will be 7507.12.0000, HTS, which provides for nickel tubes, pipes and tube or pipe fittings (for example, couplings, elbows, sleeves): tubes and pipes: of nickel alloys. The product is more specifically described by the heading of 7507 as a pipe or tube than heading 7508 as an article of. Hastelloy C276 meets Ch. 75 subheading note 1(b) for nickel alloys.
The applicable subheading for the Titanium Grade 2 nipple will be 8108.90.6075, HTS, which provides for titanium and articles thereof, including waste and scrap: other: other: other. Pipe and tube fittings are considered (in nickel, lead, zinc and tin chapters) to be items akin to pipes and tubes. Pipe and tube fittings are not considered within any of the non-ferrous metals provision, to be articles of. Accordingly, in line with the previous non-ferrous metals chapters, titanium pipe and tube fittings are classified within 8108.90.6075.
The applicable subheading for the Nickel 200 nipple will be 7507.20.0000, HTS, which provides for nickel tubes, pipes and tube or pipe fittings (for example, couplings, elbows, sleeves): tube or pipe fittings.
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 Kathy Campanelli at 646-733-3021.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division