CLA-2-84:OT:RR:NC:1:104
Mr. John Hanson
MBC Brokers Inc.
13823 Judah Ave.
Hawthorne, CA 90250-6415
RE: The tariff classification of a TorqueMaster Make/Break Unit from China
Dear Mr. Hanson:
In your letter dated December 23, 2014, on behalf of Integrated Application Engineering, you requested a tariff classification ruling.
The imported item is called a TorqueMaster Make/Break Unit which is a ratchet style horizontal torque unit that is designed to safely and efficiently assemble and disassemble threaded tubular tool joint connections of downhole tools and equipment used at downhole drilling sites. The units are hydraulic and come with a fixed headstock bed assembly, a traversing tailstock, a hydraulic control console and other options that allow for a made to order configurations. The TorqueMaster can be operated by one person and can be controlled from the console. The tailstock can carry a load of 5,000 pounds which makes handling the work piece easier. The clamp force will increase with each torque to reduce the risk of slippage during the make/break operations. The torque is applied at the axial center line of the tool in order to ensure accurate torque measurement and prevent thread damage.
In your letter, you suggest classifying the TorqueMaster Make/Break Unit model as a part in subheading 8431.43.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Parts for boring or sinking machinery of oil and gas field machinery, Other. However, the model is a machine in and of itself with the individual function of handling. In view of this fact, classification in subheading 8431.43.8060, HTSUS, as a part would not be appropriate.
The applicable subheading for the TorqueMaster Make/Break Unit will be 8428.90.0290, HTSUS, which provides for Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other. The 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 Patricia O’Donnell at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division