CLA-2-73:OT:RR:NC:N1:117

Ms. Ellen DiLapi
Customs Specialist
Sumitomo Corporation of America
1979 Marcus Avenue
Suite 220
Lake Success, NY 11042

RE: The tariff classification of steel mechanical tubing from Mexico

Dear Ms. DiLapi:

In your letter dated April 21, 2016, you requested a tariff classification ruling.

The products you intend to import are described as high end steel mechanical tubing used for automobile parts. The intended automotive parts to be produced from the imported tubing are shock absorber parts, high pressure hydraulic lines for construction equipment, suspension parts and engine mounts. In their imported condition the tubing is in material lengths and not further manufactured into automobile parts. Photos were submitted for all tubing.

To meet customer requirements for the intended use, the tubing is produced to ASTM A513 specifications with additional custom specifications. The wall thicknesses range from 1.1mm to 4.0mm. The outside diameters for all tubing are stated to be less than 40mm. Some of the tubing is cold drawn. All the tubing is nonalloy and welded.

The applicable subheading for the nonalloy steel welded cold-drawn tubing with a wall thicknesss less than 1.65mm will be 7306.30.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other tubes, pipes and hollow profiles(for example, open seamed or welded, riveted or similarly closed), of iron or steel: other welded, of circular cross section, of iron or nonalloy steel: having a wall thickness of less than 1.65mm. The general rate of duty will be free.

The applicable subheading for the nonalloy steel welded cold-drawn tubing with a wall thicknesss of 1.65mm or more will be 7306.30.5015, HTSUS, which provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: other welded, of circular cross section, of iron or nonalloy steel: having a wall thickness of 1.65mm or more: other, other, cold-drawn. The general rate of duty will be free.

The applicable subheading for the nonalloy steel welded tubing with a wall thicknesss of 1.65mm or more and an outside diameter not exceeding 114.3mm will be 7306.30.5055, HTSUS, which provides for other tubes, pipes and hollow profiles (for example, open seamed or welded, riveted or similarly closed), of iron or steel: other welded, of circular cross section, of iron or nonalloy steel: having a wall thickness of 1.65mm or more: other: with an outside diameter not exceeding 114.3mm: other, other, other. The general rate of duty will be free.

You have asked whether this product is subject to antidumping duties or countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP). You can contact them at http://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and Countervailing Duty” under “Popular Topics” at the top of the screen), and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at http://addcvd.cbp.gov/.

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 https://hts.usitc.gov/current.

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 [email protected].

Sincerely,

Deborah C. Marinucci
Acting Director
National Commodity Specialist Division