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NY 854129

July 31, 1990

CLA-2-84:S:N:N1:102 854129


TARIFF NO.: 8413.91.9090

Mr. Bill Compton
National Oilwell
P.O. Box 4638
Houston, Texas 77210-4638

RE: The tariff classification of semi-finished valve bodies for pumps from Venezuela

Dear Mr. Compton:

In your letter dated June 28, 1990 you requested a tariff classification ruling.

In your letter you outlined your company's plans to ship raw steel forgings, of U.S. origin, to your subsidiary in Venezuela. Once there these forgings would be ground and finished on CNC equipment, then heat treated to their required hardness level. The completed articles, which are referred to as "Mission Valve Body" (part number 065402509) and "National Valve Body" (part number 1560990) are parts of the intake/discharge valves found on mud pumps used in the oil exploration industry. When these units are re-imported into the United States your company will finish them by adding either a polyurethane or Buna/synthetic rubber sealing disc. The complete pump valve bodies are then sold as expendable replacement parts to drilling companies. Based on the machining and heat treatment performed, it is our opinion that the operation performed in Venezuela would be considered a substantial transformation. There would be no deduction allowed, in the appraised value of the imported finished valve parts, for the cost of the U.S. made forgings.

The applicable subheading for the mud pump valve bodies will be 8413.91.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of liquid pumps. The duty rate will be 3 percent ad valorem.

Articles classifiable under subheading 8413.91.9090, HTS, which are products of Venezuela are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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