CLA-2-84:OT:RR:NC:N1:106
Mr. Kevin Williams Attorney
Rodriquez O’Donnell
8430 W Bryn Maw Avenue
Suite 525
Chicago, IL 60631
RE: The tariff classification of Non-Magnetic Drill Collars from Japan
Dear Mr. Williams:
In your letter dated November 9, 2011 you requested a tariff classification ruling on behalf of your client Daido Steel (America) Inc.
The merchandise under consideration is non-magnetic drill collars. The non-magnetic drill collars are solely or principally used on oil and gas well drilling machinery. They are sold to both the offshore and onshore drilling industries with anticipation of the majority of sales will be to the offshore drilling industry.
Product 1- The steel would be cut into 31 foot lengths and a circular hole would be drilled through the length of the steel to create a non-magnetic steel drill collar. At the time of importation the drill collars meet all the standard of API Specification 7-1¹ except those for end threads. The threads are cut into the drill collars after importation.
Product 2- The steel would be cut into 31 foot lengths and a pilot hole would be drilled into each end of the bar to create a drill collar. At the time of importation, the unfinished drill collars meet al the standards of API Specification 7-1¹ except those for end threads and the internal diameter. After importation, a circular hole would be drilled through the length of the steel and the threads would be cut.
Product 3-The steel would be cut into 31 foot lengths in Japan and Daido Steel (America) Inc. would import the drill collars into the U.S. At the time of importation, the unfinished drill collars meet al the standards of API Specification 7-1¹ except those for end threads and the internal diameter. After importation, a circular hole would drill through the length of the steel and threads would be cut.
The applicable subheading for the non-magnetic drill collars used for offshore drilling applications will be 8431.43.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “ Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: of machinery of heading…8430: Parts for boring or sinking machinery of subheading … 8430.49: Of offshore oil and natural gas drilling and productions platforms.” The general rate of duty will be Free.
The applicable subheading for the non-magnetic drill collars used for onshore drilling applications will be 8431.43.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “ Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: of machinery of heading…8430: Parts for boring or sinking machinery of subheading … 8430.49: Other: Other.” The general rate of duty will be Free.
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 Matthew Sullivan at (646) 733-3013.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division