CLA-2-73:OT:RR:NC:1:117
Robert A. MacDonald, CCS
Customs and Trade Consultant
MSR Customs and Commodity Tax Group
2 Tippett Road
Toronto, Ontario, Canada
M3H 2V2
RE: The tariff classification of malleable iron pipe fittings from Thailand
Dear Mr. MacDonald:
In your letter dated November 1, 2010 you requested a tariff classification ruling on behalf of your client Ferguson Enterprises Inc.
The products you intend to import are described as galvanized malleable iron socket couplings. The products are described as produced in a casting process meeting the requirements of ASTM A197/A47 and then further processed by additional steps such as threading and galvanizing. The couplings are internally threaded at both ends in order to attach the bores of two lengths of pipe together.
You suggest classification in 7307.92.3010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for threaded elbows bends and sleeves: sleeves (couplings) of iron or nonalloy steel.
This office does not agree with your suggested classification. It is our opinion that the cast galvanized malleable iron pipe fittings are more specifically provided for elsewhere. There are precedents for classifying other galvanized malleable, as well as nonmalleable, cast iron tube or pipe fittings as tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel in accordance with the method of manufacture as cast fittings in 7307.11.00, HTSUS through 7307.19.90, HTSUS depending upon constituent material and specific type of fitting.
The applicable subheading for the galvanized malleable iron socket couplings will be 7307.19.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: Cast fittings: other, other, other, other, threaded. The rate of duty will be 6.2 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
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 Mary Ellen Laker at (646) 733-3020.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division