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NY K81813

December 30, 2003
CLA-2-73:RR:NC:1:117 K81813


TARIFF NO.: 7326.90.8587

Mr. Jeffrey B. Jordan
Wellstream International Limited
1700 C Avenue
Port Panama City, FL 32401

RE: The tariff classification of unassembled steel end fittings from Brazil.

Dear Mr. Jordan:

In your letter dated December 9, 2003 you requested a tariff classification ruling.

The items to be imported are alloy steel end fittings used primarily in the offshore oil and gas industry for both topside and subsea applications. Used in conjunction with a flexible pipe made of alternating plastic and steel layers, the subject fittings are designed to terminate each pipe layer and provide the required connection to mate with the customer’s production facilities. Consisting of a body, a jacket, inner and outer collars, inner and outer seal rings and either a fixed or swivel flange, these end fittings are assembled after importation.

In HQ ruling 088393 dated March 26, 1991, a copy of which is attached, it was held that "hose fittings" are classifiable under heading 7326, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel and that metal (iron or steel) pipe fittings for PVC plastic pipe are properly classifiable under heading 7307, HTS, which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel. This ruling made clear the distinction between pipes and tubes, and hose. A pipe or tube is made of a single extruded compound such as PVC or metal. A hose, however, is comprised of many materials (2 or more). Therefore, the layered steel and plastic flexible pipe described in your inquiry is considered hose and the subject end fittings are to be considered hose fittings.

The applicable subheading for the steel end fittings will be 7326.90.8587 Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

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 Paula Ilardi at 646-733-3020.


Robert B. Swierupski

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