CLA-2-83:OT:RR:NC:N1:121
Mr. Robert G. Gaydo
Deringer Logistics Consulting Group
6930 Metroplex Drive
Romulus, MI 48174
RE: The tariff classification of trailers from Canada
Dear Mr. Gaydo:
In your letter dated October 29, 2013, you requested a tariff classification ruling on behalf of Trican Well Service Ltd.
The merchandise under consideration is four trailers designed for use in the oil and gas exploration industry; specifically for use in fracing and cementing operations. In each case, the trailer must be connected to a tractor or another external device in order to perform offloading operations. The tractor, however, will not be imported with the trailer.
The first trailer, referred to as a “Sand Can” and/or “Sand End-Dump Trailer,” is a fully enclosed, hydraulically raised/lowered, end-dump trailer designed for transporting dry sand to a work site and dumping it as needed. This trailer has four compartments to accommodate sand of different sizes for various on-site jobs. It is designed to haul 25 tons of sand on the road and can hold up to 30 tons when stationary. To power the hydraulic components, the Sand Can/Sand End-Dump Trailer must be connected to a tractor with a wet kit and power takeoff (PTO).
The second trailer, referred to as a “Sand Pneumatic Trailer,” is a fully enclosed, pressurized (for unloading), non-dumping trailer designed to transport sand and offload it into a Sand Hogg, Sand Bin or Sand Can. The Sand Pneumatic Trailer is loaded through the top via manholes or through the bottom by blowing the sand in under pressure. Because the trailer is not internally powered, it must be connected to a tractor equipped with a PTO and a blower, or to another external device to pressurize the tank for unloading. Once on site and pressurized, the sand is disbursed through a 4 or 5 inch discharge hose.
The third trailer, referred to as a “Cement Bulk Pneumatic Trailer,” is a fully enclosed, pressurized (for unloading), non-dumping trailer designed to transport dry cement to the worksite and offload it into another vessel, tank or cement mixer/pumper. It can be loaded from the top via manholes, from the bottom by being blown in through 4 inch valves, or under pressure through the side camloks located on the bottom of the hopper. Because the trailer is not self-powered, it must be connected to a blower equipped tractor or another external blower to pressurize the tank for unloading.
The applicable subheading for the Sand Can/Sand End-Dump Trailer, the Sand Pneumatic Trailer and the Cement Bulk Pneumatic Trailer will be 8716.39.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for trailers and semi-trailers…other trailers and semi-trailers for the transport of goods, other, other, other, other. The duty rate will be free.
This office is precluded from ruling on the Twin Cementer Pumper Trailer because similar merchandise is currently under review in our Headquarters office. Since a similar issue is
pending before Customs and Border Protection (CBP), a ruling cannot be issued until the matter is resolved.
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 Barbara Kaiser at (646) 733-3024.
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division