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NY J81316




March 18, 2003

CLA-2-73:RR:NC:1:117 J81316

CATEGORY: CLASSIFICATION

TARIFF NO.: 7307.22.1000; 7307.23.0000; 7507.20.0000; 8108.90.6075; 8109.90.0000

Ms. Shelley Vybiral
Snap-tite Inc.
8325 Hessinger Drive
Erie, PA 16509

RE: The tariff classification of ferrous and nonferrous tube fittings.

Dear Ms. Vybiral:

In your letter dated February 13, 2003, you requested a tariff classification ruling.

The products to be imported include stainless steel, nickel, titanium Grade 2 and zirconium tube/pipe fittings known as couplings. These couplings are used to join two pieces of tubing, normally used in the high-pressure fluid industry. You state that the couplings are not used to connect hose. Different connection types are available. The couplings may be threaded on both ends or they may have beveled ends (butt-weld). Some couplings may be threaded on one end and beveled on the other end for a welding connection.

The applicable subheading for the stainless steel threaded couplings will be 7307.22.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, of stainless steel, threaded elbows, bends and sleeves, sleeves (couplings).

The applicable subheading for the stainless steel butt weld fittings will be 7307.23.0000, HTS, which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, of stainless steel, butt welding fittings.

The applicable subheading for the stainless steel couplings having one threaded end and one butt weld end will be 7307.23.0000, HTS, which provides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel, other, of stainless steel, butt welding fittings.

You indicate that you believe the proper classification for the stainless steel couplings is 7307.22.1000. This subheading specifically describes threaded couplings. HTS subheading 7307.23.00 specifically describes butt welding fittings. Since both of these subheadings specifically describe the couplings having one threaded end and one butt weld end, these fittings will be classified in accordance with General Rule of Interpretation 3(c) which states that when goods are classifiable under two or more headings and cannot be classified by reference to GRI 3(a)--the heading which provides the most specific description--or 3(b)--mixtures, composite goods, sets-- they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration. GRI 6 (I) states that Rules 1 to 5 govern, mutatis mutandis, classification at subheading levels within the same heading.

The applicable subheading for the nickel couplings will be 7507.20.0000, HTS, which provides for nickel tubes, pipes and tube or pipe fittings (for example, couplings, elbows, sleeves): tube or pipe fittings.

The applicable subheading for the titanium Grade 2 couplings will be 8108.90.6075, HTS, which provides for titanium and articles thereof, including waste and scrap: other: other: other. Pipe and tube fittings are considered (in nickel, led, zinc and tin chapters) to be items akin to pipes and tubes. Pipe and tube fittings are not considered within any of the non-ferrous metals provisions to be articles of. Accordingly, in line with the previous non-ferrous metals chapters, titanium pipe and tube fittings are classified within 8108.90.6075.

The applicable subheading for the zirconium couplings will be 8109.90.0000, HTS, which provides for zirconium and articles thereof, including waste and scrap: other.

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

You also requested a classification ruling on sleeved connections. We would like to see a sample of the sleeved connection before we issue a ruling.

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 (heading 7307) or National Import Specialist Kathy Campanelli at 646-733-3021 (headings 7507, 8108 and 8109).

Sincerely,

Robert B. Swierupski
Director,

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