CLA-2-84:OT:RR:NC:N1:104
Mr. Brandon J. Chesnut
E&M Supply Group
P.O. Box 956
Breaux Bridge, LA 70517
RE: The tariff classification of HDD Drill Pipes Fitted with Tool Joints from an unspecified country
Dear Mr. Chesnut:
In your letter dated March 27, 2018, you requested a tariff classification ruling.
You are importing drill pipes that are fitted with tool joints. They are also known as “finished” drill pipes. The finished drill pipe is made of steel parts and all heat treatment, welding, assembling, and post-production work has been completed before being shipped in its completed form. The working/drilling/threaded ends are said to have been welded (fitted) to both ends of the tube. This finished drill pipe is used in the Horizontal Directional Drilling (HDD) industry for installation of underground utilities for drilling holes underneath rivers, roads, and other obstacles where trenching is not feasible. The finished drill pipe is powered by the rig and is used to rotate and push the drill bit into the drilling hole. Then it is used to push and pull the reamers through the hole in order to widen the hole to its specific diameter. The finished drill pipe then pulls the final product (a conduit) into the tunnel to finish the installation.
In your ruling submission you had stated that you were advised by a Customs Officer that the classification should be under subheading 7304.59, Harmonized Tariff Schedule of the United States (HTSUS) which provides for Tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, however this office finds that drill pipe fitted with tool joints is made up into a specific identifiable article. As per the Explanatory Notes (ENs), heading 7304 excludes tubes, pipes and hollow profiles made up into specific identifiable articles, e.g., other machinery parts of Section XVI. Historically, drill pipe fitted with tool joints have been classified as machine parts of heading 8431, HTSUS.
The applicable subheading for the finished HDD Drill Pipe Fitted with Tool Joints will be 8431.43.8040, HTSUS, which provides for “Parts, suitable for use solely or principally with the machinery of headings 8425 to 8430: Parts for boring or sinking machinery of subheading 8430.41 or 8430.49: Other: Drill pipe fitted with tool joints”. 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 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 Patricia O’Donnell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division