CLA-2-73:OT:RR:NC:N1:113
Mr. Josh Beker Givens & Johnston, PLLC 950 Echo Lane, Suite 360 Houston, TX 77024-2788
RE: The tariff classification of True Taper coils from France or Japan
Dear Mr. Beker:
In your letter dated April 25, 2019, on behalf of your client Quality Tubing, a division of National Oilwell Varco, L.P., you requested a tariff classification ruling. In response to our request for additional information, this office received answers to our questions in your letter dated September 10, 2019. Pictures and product specification sheets were provided with your ruling request.
The subject merchandise identified as National Oilwell Varco, L.P’s True Taper coils consists of hot rolled, high strength, low alloy steel coils in the pickled and oiled condition, for use in the manufacture of coil tubing. The True Taper coils are tapered along the length of the coil. The coils are larger on one end and smaller on the other end. You stated in your letter that the “True Taper coils will be supplied with the 10% length of one end rolled to a larger thickness and 10% of the other end rolled to a smaller thickness. The steel between the two ends tapers along its length. The hot rolled coils will be made from a ladle-refined continuously-cast process...The coils will be slit to the appropriate width. The slit steel strips are then joined together end to end…The joined strips are then formed into Coiled Tubing.”
You suggest classification of the True Taper coils in subheading 7225.30, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Flat-rolled products of other alloy steel, of a width of 600 mm or more: Other, not further worked than hot-rolled, in coils. However, based on the product dimensions and resulting “tapered” configuration, these hot rolled products are neither flat nor rectangular and do not meet the Chapter 72, Note 1 (k) definition of flat rolled products. Consideration was also given to classification in heading 7228 as either Other bars and rods of other alloy steel or angles, shapes and sections, of other alloy steel. However, the coils fail to meet the requirements of Chapter 72 Notes 1 (m) or (n), as they do not possess a uniform solid cross-section along their whole length. Therefore, the True Taper coils will be classified in heading 7326, HTSUS, which provides for other articles of iron or steel.
The applicable subheading for National Oilwell Varco, L.P’s True Taper coils will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other, other…other. The rate of duty will be 2.9 percent ad valorem.
Regarding the applicability of Section 232 duties, noting that the correct provision under the HTSUS for the subject True Taper coils is subheading 7326.90.8688, Section 232 duties are not applicable.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division