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NY 888153

July 21, 1993



TARIFF NO.: 8431.43.4000

Mr. Robert Garcia
R.W. Smith & Co., Inc.
P.O Box 60587 AMF
Houston, TX 77205-0587

RE: The tariff classification of parts of Jack-up rigs from Japan

Dear Mr. Garcia:

In your letter dated July 7, 1992, on behalf of Marubeni Tubulars
Inc., Houston, TX, you requested a tariff classification ruling. You have submitted a descriptive brochure.

You state the imported products are called racks and chords, which are components of Jack-up rig legs. Jack-up rigs are widely used offshore drilling rigs which are used for drilling in shallow waters (approximately 120m). This rig consists of a hull, drilling equipment, a jacking system and legs. There are two types of legs in use: the triangular type and the caisson type. When the rig arrives at the site, the legs are jacked down to the seabed to fix the rig in place and elevate the hull. In order to support the enormous weight of the rig, the legs are constructed of specialty steels.

The racks and chords are integral components of the offshore drilling rigs (segments of the legs). Usually, heavy plate (120- 200 mm thick) of 80 kgf/mm 2 class high-tensile strength steel is used for the racks. Their ductility values meet requirements from normal to arctic temperatures.

Steel materials used for the cords have strengths equal to those of steels for the racks. Jack-up Rigs are used in locations where sea and weather conditions are severe. To minimize the effects of tide and wave height in such locations, chord materials of smaller diameter and greater thickness may be required.

The applicable subheading for the racks and chords (parts of legs for Jack-up Rigs) will be 8431.43.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of offshore oil and natural gas drilling and production platforms. The rate of duty will be 5.7 percent ad valorem. 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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