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NY K86336

June 14, 2004
CLA-2-73:RR:NC:1:117 K86336


TARIFF NO.: 7307.19.30; 7325.99.10

Mr. Rayburn Berry
Givens & Johnston PLLC
950 Echo Lane, Suite 360
Houston, Texas 77024-2788

RE: The tariff classification of cast pipe fittings from China.

Dear Mr. Berry:

In your letter dated May 14, 2004 on behalf of Dresser Piping Specialties, you requested a tariff classification ruling. A catalog and CDs showing photographs of the products under consideration were submitted with your ruling request.

The products under consideration include five types of cast pipe fittings: Dresser Style 253 cast couplings, long sleeve cast couplings and cast reducing couplings, Dresser Style 227 cast flanged adapters and Dresser Style 231 cast line cap couplings. The couplings, known as wide range couplings, can accommodate a wide range of pipe sizes. Style 253 couplings, used to join waterworks piping of steel, cast or ductile iron, asbestos-cement and PVC, consist of a cylindrical middle ring or body of ductile iron, two follower rings of ductile iron, two gaskets of rubberized material, and a set of steel trackhead bolts and accompanying steel hex nuts. All the components except the bolts and nuts are made in China. The center ring has a conical flare at each end to receive the wedge portion of the gaskets. The two follower rings confine the outer ends of the gaskets. When the bolts are tightened, the follower rings are drawn toward each other, compressing the gaskets and forming a leak proof seal. The reducing coupling connects pipes of different diameters.

Style 227 cast flanged adapters consist of a large adapter body of ductile iron with a flange on one end, a follower ring of ductile iron which will fit on the other end of the adapter body, a gasket of rubberized material which will be compressed by the follower ring, four steel trackhead bolts with accompanying steel hex nuts which will be placed vertically along the fitting body and two bolts which will be placed horizontally. The cast flanged adapter is used for connecting pumps, filters and valves to pipes of steel, cast or ductile iron, PVC and asbestos-cement. When the vertical bolts are tightened, the follower ring compresses the gasket into the conical flare on the open/non-flanged end of the adapter body creating a leak proof seal. The horizontal bolts help fix the pipe in place. All components of this fittings except for the nuts and bolts are made in China.

Style 231 cast line cap couplings, used in line terminations, consist of a large end cap of ductile iron which is flared on its open end, a follower ring of ductile iron, a rubberized gasket, and six steel trackhead bolts and steel hex nuts. When the bolts are tightened, the follower ring compresses the gasket into the flared portion of the end cap, creating a leak proof seal with the pipe.

Your request concerns the classification of the complete or fully assembled fittings, the “principal components” of each fitting, that is, the center ring, the adapter body and the end cap, when imported separately, and the remaining components of each fitting when imported separately. You express the opinion that both the complete fittings and the “principal components”, when imported separately, are classifiable as cast ductile fittings under HTS heading 7307. You believe that the center ring, adapter body and cap possess the essential character of pipe fittings and are classifiable as such. We agree with this position and note HQ ruling 082236 dated November 22, 1988. In this ruling, it was held that center rings and flanged coupling adapter bodies that were very similar to the products presently under consideration “are the very essence of the completed fittings” and are classifiable under the provision for pipe and tube fittings of iron or steel. You also express the opinion that the follower rings are classifiable as other cast articles of iron or steel under HTS subheading 7325.

The applicable subheading for both the complete or fully assembled fittings of ductile cast iron and the “principal components”, center ring, adapter body and cap, of ductile cast iron will be 7307.19.30, Harmonized Tariff Schedule of the United States (HTS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, cast fittings, other, ductile fittings. The rate of duty will be 5.6 percent ad valorem.

The applicable subheading for the cast iron follower rings will be 7325.99.10, HTS, which provides for other cast articles of iron or steel, other, other, of cast iron. The rate of duty will be free.

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

We cannot issue a binding classification ruling at this time on the steel nuts and bolts or on the gaskets. Please provide representative samples and the dimensions of the bolts and nuts. With regard to the gaskets, you describe them as being made of “rubberized material”. There is insufficient information to determine the components material of the gaskets. If the material is rubberized textile, please indicate the weight of the rubberized textile material in grams per square meter and provide a breakdown by weight of the textile versus the rubber material. If not rubberized textile, please provide a complete and specific name of the material so that we may determine if it meets the Chapter 40 Note 4 definition of synthetic rubber. Depending on the type of material, additional information may be necessary before we can classify.

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 (NIS) Paula Ilardi at 646-733-3020 (ductile iron fittings and ductile iron components), NIS Kathy Campanelli at 646-733-3021 (nuts and bolts) or NIS Joan Mazzola at 646-733-3023 (gaskets).


Robert B. Swierupski

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