CLA-2-82:RR:NC:1:104 J84700

Ms. Shelley Vybiral
Snap-Tite, Inc.
8325 Hessinger Dr.
Erie, PA 16509

RE: The tariff classification of coning and threading tools from the U.S. and other countries

Dear Ms. Vybiral:

In your letter dated May 9, 2003 you requested a tariff classification ruling.

The coning tool (part # MCTM4) is used to cut cone shapes on the end of metal tubing having diameters from ¼” to 9/16”. The tool comes with one coning cutter and one collet. The tool itself consists of a handle, cutter support, feed nut, coning tool housing and collet nut. The tool can be used on different sizes of tubing by changing the collet and the cutter. A customer only has to purchase a complete coning tool once. If tubing of a different size has to be cut, one only has to purchase the appropriate size cutter and collet.

In addition to the classification of a complete coning tool, you are requesting the classification of the collet and coning cutter imported separately as well as the classification of a separately imported threading die and guide bushing. The latter two items are used with a threading tool. (The classification of a complete threading tool is not at issue here.) Samples of these four items have been provided and will be returned.

The collet (part # 90248), as noted above, is used to hold the metal tubing in place in the coning tool. It is not dedicated for use with the coning tool. You have indicated that this type of collet can be used on a lathe in conjunction with a flex collet nut and collet chuck. It appears to be a type of work holder principally used with machine tools.

The coning cutter (part # 101F1577) and the threading die (part # P-0214) are, as noted above, the interchangeable tools for the coning tool and threading tool respectively. The composition of the cutting part of both of these interchangeable tools is tool steel.

The guide bushing (part # 1010-0343) is designed specifically for the threading tool (part # 402). This item, made of steel, locates and centers the tubing during its insertion into the tool.

The applicable subheading for the complete coning tool (part # MCTM4) will be 8205.59.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for handtools (including glass cutters) not elsewhere specified or included …: other handtools (including glass cutters) and parts thereof: other: pipe tools, and parts thereof. The general rate of duty will be 7.2 percent.

The applicable subheading for the separately imported collet (part # 90248) will be 8466.20.8035, HTS, which provides for parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders …: work holders: other. The general rate of duty is 3.7 percent.

The applicable subheading for the coning cutter (part # 101F1577) will be 8207.90.4500, HTS, which provides for interchangeable tools for handtools, whether or not power operated, or for machine tools …: other interchangeable tools, and parts thereof: other: other: suitable for cutting metal, and parts thereof. The general rate of duty will be 4.8 percent.

The applicable subheading for the threading die (part # P-0214) will be 8207.40.6000, HTS, which provides for interchangeable tools for handtools, whether or not power operated, or for machine tools …: tools for tapping or threading, and parts thereof: other. The general rate of duty will be 4.8 percent.

The applicable subheading for the guide bushing (part # 1010-0343) will be 7326.90.8587, HTS, which provides for other articles of iron or steel: other: other: other: other. The general rate of duty will be 2.9 percent.

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 Robert Losche at 646-733-3011.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division