CLA-2-84:OT:RR:NC:1:104
Mr. George M. Keller
Customs Advisory Services, Inc.
100 Hartsfield Centre Pkwy.
Suite 350
Atlanta, GA 30354
RE: The tariff classification of a Test Plug from an unknown country
Dear Mr. Keller:
In your letter dated February 28, 2013, on behalf of FMC Technologies, Inc., you requested a tariff classification ruling.
Casing head assembly Model C-22-EG is designed to support drilling wellhead and completion equipment. It is the lowest part of the wellhead assembly and is generally connected to the surface casing string. The main components of this assembly are the casing head body, the test plug and locking bolts with nuts. The casing head assembly is said to (a) provide attachment to the surface casing string, (b) support blowout preventers while the hole is drilled for the next casing string, (c) provide for suspending and packing of the next casing string, (d) contain outlets for annular access and (e) provide for testing blowout preventers while drilling. The casing head body is alloy steel. The test plug is made of either stainless steel or alloy steel. The locking bolts and nuts are stainless steel.
You have requested a ruling as to the tariff classification of this merchandise under the following two scenarios: (a) the casing head assembly imported complete and (b) the parts imported separately.
The test plug is a steel valve that attaches into the casing head body. The test plug contains a ball and a pressure gauge that is attached to the end of the plug. The pin in the pressure gauge forces the ball to open and measures the pressure in the line. The valve closes when the pressure gauge is removed so that pressure does not escape. If the pressure gets too high, it can be relieved through the plug. The test plug is a one directional nonreturn valve meaning that pressure cannot be added through the test plug.
The applicable subheading for the Test Plug will be 8481.30.2090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: check (nonreturn) valves: of iron or steel...of steel. The general duty rate will be 5 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/.
Your inquiry does not provide enough information for us to give a classification ruling on a casing head assembly, the casing head body and the locking bolts and nuts. Your request for a classification ruling should include:
What, if any, mechanical features are present in the (a) casing head assembly and (b) casing head body? What mechanical processes take place in these articles?
Does the casing head apply or modify force or does it act as a static housing from which other devices can be suspended?
You mention that the casing head assembly provides for suspending and packing of the next casing. What is the function of the packing? Does the packing expand and, if so, what process causes this expansion?
The casing head body contains a test port. What is the function of the test port? How is the hydraulic pressure applied through the test port? Are there any mechanical features or is it passive? (If mechanical, please describe the function)
You mention the bolts and nuts are imported separately.
(a) Please provide samples and dimensional diagrams of the locking bolts and nuts.
(b) Submit a labeled diagram depicting where the locking bolts and nuts are used within the casing head assembly.
(c) Will an equal number of locking bolts and nuts be included in one shipment? (d) How are the bolts installed?
(e) Can they be torqued by the head?
Please provide a country of origin for the casing head assembly, casing head body and the bolts with the nuts.
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division