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NY 862242


April 17, 1991

CLA-2-39:S:N:N3G:221 862242

CATEGORY: CLASSIFICATION

TARIFF NO.: 3917.31.0000; 3917.39.0010

Mr. Roger L. Hiatt
Miller & Steuart
2320 Commerce Tower
911 Main Street
Kansas City, Missouri 64105

RE: The tariff classification of high pressure flexible pipe.

Dear Mr. Hiatt:

In your letter dated March 29, 1991, on behalf of Wellstream Corporation, you requested a tariff classification ruling.

The pipe is made of alternating layers of plastics material and interlocked steel reinforcement. The polymer is generally nylon, but another polymer may be used depending on the specifications of the pipe. The steel reinforcement will usually be in the form of strips or bands. The pipe is imported in lengths exceeding 5000 feet and in various diameters. It is wound on reels that are 20 feet high and 18 to 20 feet wide. The pipe is currently used in the offshore petroleum and gas industry, primarily to transport oil and gas from subsea satellite oil well to supporting platform, from platform to platform, or from platform to shore. The pipe may have pressure ratings up to 12000 psi or 83 MPa. You are planning to manufacture the pipe in a Foreign Trade Zone using materials from various countries.

The applicable subheading for the pipe, when having a minimum burst pressure of 27.6 MPa, will be 3917.31.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for flexible tubes, pipes and hoses, of plastics, having a minimum burst pressure of 27.6 MPa. The rate of duty applicable to importations from countries with most favored nation status will be 3.1 percent ad valorem.

The applicable subheading for the pipe, when having a minimum burst pressure below 27.6 MPa, will be 3917.39.0010, HTS, which provides for other tubes, pipes and hoses of plastics, other, reinforced with metal. The rate of duty applicable to importations from countries with most favored nation status will be 3.1 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.

Sincerely,

Jean F. Maguire
Area Director

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