CLA-2-74:OT:RR:NC:N1:117
Ms. Ruth N. Girmscheid
International Customs Services, Inc.
N64-24801 Main Street, Suite 121
Sussex, WI 53089
RE: The tariff classification of risers from an unspecified country
Dear Ms. Girmscheid:
In your letter dated March 13, 2018, you requested a tariff classification ruling on behalf of your client, Johnson Controls Canada LP (aka Skymark International).
The products under consideration are identified as "risers". The risers are said to consist of up to a 10-foot copper alloy (brass) seamless pipe with fittings and a tee connected to a manual shut-off ball valve. They are installed in the walls of a building and are used to transport water which is used for heating and cooling a room to and from the coils in a heat pump system.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. We find that the subject risers are composite goods, the essential character of which is imparted by the copper alloy tubing which predominates by weight and is the component in the heat pump system that transports the water that is used to heat/cool rooms.
You suggest classification of the risers in subheading 7419.99.5010, HTSUS, which provides for other articles of copper, other, other, other, brass plumbing goods not elsewhere specified or included. However, this office finds that the risers are more specifically provided for as a copper pipe/tube in heading 7411, HTSUS.
The applicable subheading for the risers will be 7411.21.1000, HTSUS, which provides for copper tubes and pipes, of copper alloys, of copper-zinc base alloys (brass), seamless. The general rate of duty will be 1.4 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 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,
Steven A. Mack
Director
National Commodity Specialist Division