CLA-2-73:RR:NC:1:117 J81441
Ms. Shelley Vybiral
Snap-tite Inc.
8325 Hessinger Dr.
Erie, PA 16509
RE: The tariff classification of steel and nickel tube fittings.
Dear Ms. Vybiral:
In your letter dated February 17, 2003, you requested a tariff classification ruling.
The products to be imported are alloy steel, stainless steel and nickel welding couplings used to connect tubes. Chemical compositions and illustrations of the couplings were provided. The products you describe as alloy steel fittings include the following grades or types of steel: SAE 4130, 2205 Duplex and A105/A105N. You believe the proper classification of the products you describe as alloy steel couplings is 7307.92.3030. The products you describe as stainless steel fittings are Type 316 stainless steel. You believe the proper classification of the stainless steel couplings is 7307.22.1000. The products you describe as Inconel 625 fittings are nickel alloy fittings.
Grades 4130 and A105/A105N steel meet the definition for other alloy steel in HTS Chapter 72 Note 1. (f). Type 2205 Duplex steel contains 0.030 % max. carbon and from 21.0% to 23.0% chromium and therefore meets the Chapter 72 Note 1. (e) definition for stainless steel: “Alloy steels containing, by weight 1.2 percent or less of carbon and 10.5 percent or more of chromium, with or without other elements. The classifications you suggest for both the alloy steel and stainless steel couplings provide for threaded elbows, bends and sleeves. The couplings are weld end couplings. There are specific subheadings for butt welding fittings.
The applicable subheading for Grades 4130 and A105/A105N alloy steel welding fittings will be 7307.93.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, butt welding fittings, with an inside diameter of less than 360 mm, of alloy steel (except stainless steel).
The applicable subheading for Types 316 and 2205 Duplex stainless steel welding fittings will be 7307.23.0000, HTS, which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, of stainless steel, butt welding fittings.
The applicable subheading for Inconel 625 nickel alloy welding fittings 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 Paula Ilardi at 646-733-3020 (heading 7307) or National Import Specialist Kathy Campanelli at 646-733-3021 (heading 7507).
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division