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NY J89776




November 13, 2003

CLA-2-73:RR:NC:1:117 J89776

CATEGORY: CLASSIFICATION

TARIFF NO.: 7307.92.3010; 7307.92.3030, 7326.90.8505; 8481.80.3090; 8481.90.3000

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

RE: The tariff classification of various steel couplings and parts and from Ireland.

Dear Ms. Vyrbiral:

In your letter dated October 14, 2003 you requested a tariff classification ruling on various steel couplings and parts used in hydraulic, pneumatic and general purpose applications. Representative samples were submitted with your request and will be returned to you.

Item 1 is a steel fitting which has external threads on one side and internal threads on the other. Called a quick disconnect coupling, this fitting consists of a male nipple piece and a female coupler piece made up of a sleeve and fitting body. It can be used to connect either a metal tube or a hose comprised of many materials.

Item 2 is referred to as a steel fitting body. It is part of the female portion of the above mentioned quick disconnect coupling, and is imported in an unfinished condition.

Also referred to as a steel quick disconnect coupling, Item 3 is a complete hand operated valve which is comprised of both a male nipple and female coupler piece which consists of a sleeve and fitting body. Internally threaded with valve mechanisms on the inside of each end, this item is used to stop the flow of liquid when disconnected.

Item 4 is also called a steel fitting body. It is part of the female portion of the quick disconnect coupling described in Item 3, and is unfinished as imported.

All of these steel items are dichromate coated and available in AISI 1144 or AISI 12L14. Although both grades are considered carbon steels, AISI 1144 contains manganese in the range of 1.35-1.65. As per Chapter 72 Note 1 (f) of the Harmonized Tariff Schedule (HTS), any steel not complying with the definition of stainless steel and containing 1.65 percent or more of manganese is considered an alloy steel for classification purposes.

The applicable subheading for the steel quick disconnect coupling fitting (Item 1) with a manganese content of less than 1.65 will be 7307.92.3010 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, threaded elbows bends and sleeves, sleeves(couplings), of iron or nonalloy steel. The rate of duty will be 0.6 percent ad valorem.

The applicable subheading for the steel quick disconnect coupling (Item 1) with manganese content of 1.65 will be 7307.92.3030, 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, threaded elbows bends and sleeves, sleeves(couplings), of alloy steel(except stainless). The rate of duty will be 0.6 percent ad valorem.

On March 5, 2002, President Bush proclaimed additional tariffs and quotas on a number of steel mill products for a period of three years. Products classified under HTS subheadings 7307.92.3010 and 7307.92.3030, unless specifically excluded, are subject to additional duties. See subheadings 9903.73.88 through 9903.73.95, copy attached. Although hydraulic fittings are excluded, any other fitting falling into these subheadings may be not be. In this case, the applicable Chapter 99 subheading is 9903.73.94 which currently carries an additional 10 percent ad valorem tariff. At the time of importation, you must report this Chapter 99 number in addition to the Chapter 73 number listed above.

The applicable subheading for the unfinished steel fitting body (Item 2) will be 7326.90.8505, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

The applicable subheading for the steel quick disconnect coupling with the valve mechanism (Item 3) will be 8481.80.3090 Harmonized Tariff Schedule of the United States (HTS)which provides for taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves, parts thereof, other appliances, hand operated, of iron or steel, of steel, other. The rate of duty will be 5.6 percent ad valorem.

The applicable subheading for the unfinished steel fitting body (Item 4) will be 8481.90.3000 Harmonized Tariff Schedule of the United States (HTS)which provides for taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves, parts thereof, parts, of hand operated and check appliances, of iron or steel. The rate of duty will be 5 percent ad valorem.

You also ask about the classification of an unfinished steel fitting body when not dedicated for use with any particular type of fitting. The applicable subheading for this fitting body will be 7326.90.8505, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, 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.

Sincerely,

Robert B. Swierupski
Director,

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