CLA-2-73:RR:NC:1:117 G88427

Mr. Robert Rogers
Circle International, Inc.
8592 N.E. Alderwood Road
Portland, Oregon 97220

RE: The tariff classification of steel fittings from China.

Dear Mr. Rogers:

In your letter dated March 1, 2001 on behalf of API International, Inc., you requested a tariff classification ruling.

The products to be imported are 90-degree elbows made to ASTM Specification A 234. You state in your ruling request that these elbows are nonmalleable cast iron, not threaded and not butt-weld. However, ASTM Spec A234 is the Standard Specification for Piping Fittings of Wrought Carbon Steel and Alloy Steel for Moderate and High Temperature Service. You later confirmed that these fittings are wrought and are butt-weld fittings. According to the mill test certificate, these fittings are nonalloy steel. They range from 4 inches to 12 inches in diameter.

The applicable subheading for the nonalloy steel butt-weld elbow pipe fittings will be 7307.93.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, butt welding fittings, with an inside diameter of less than 360 mm, of iron or nonalloy steel. The rate of duty will be 6.2 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

You may want to check whether this product is subject to antidumping duties or countervailing duties. A list of AD/CVD proceedings at the Department of Commerce (DOC) and their product coverage can be obtained from the DOC website at: http://ia.ita.doc.gov, or you may write to them at the U.S. Department of Commerce, International Trade Administration, Office of Antidumping Compliance, 14th Street and Constitution Avenue, N.W., Washington, DC 20230. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs.

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 Paula Ilardi at 212-637-7016.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division