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NY N004702

January 12, 2007



TARIFF NO.: 7304.51.5060; 7326.90.8587

Larry E. Branch
FMC Technologies
2825 West Washington
Stephensville, TX 76401

RE: The tariff classification of pup joints and C&C hoses from India or China.

Dear Mr. Branch:

In your letter dated December 20, 2006 you requested a tariff classification ruling.

The items to be imported are referred to as pup joints and C&C hoses. A pup joint is a seamless cold-drawn alloy steel pipe that is threaded on one end and fitted on the other end with a wing union nut. The function of the pup joint is to connect two pieces of high-pressure equipment. A C&C hose is comprised of two pieces of seamless cold-drawn alloy steel piping connected by a wing union nut and swivel joints. Though in the form of a loop when in the closed position, the nut can be undone and the pipe can be rotated to the desired direction. Like the pup joint, the C&C hose is used for connecting high-pressure equipment. In addition, this loop can be used as a means of connecting either two pieces of pipe or two valves together in high-pressure applications.

Pup Joint C&C Hose

The applicable subheading for the pup joints will be 7304.51.5060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel, other, of circular cross-section, of other alloy steel, cold-drawn or cold-rolled (cold-reduced), other, other, other. The rate of duty will be free.

The applicable subheading for C&C hoses will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTSUS), 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.

In your letter, you suggest classifiying the C&C (cementing and circulating) hose as a pipe/tube under subheading 7304.51.5060. This hose is not merely lengths of pipe with fittings attached. Rather, this fabrication is made up into a specific identifiable article which can be folded up for transportation and storage. As such, it would be excluded from classification under any of the pipe/tube headings in Chapter 73.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Gloria Stingone at 646-733-3020.


Robert B. Swierupski

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