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NY N018132




November 2, 2007

CLA-2-84:OT:RR:NC:1:104

CATEGORY: CLASSIFICATION

TARIFF NO.: 8479.89.9850

Ms. Marian E. Ladner
Epstein Becker Green Wickliff & Hall, P.C. Wells Fargo Plaza
1000 Louisiana, Suite 5400
Houston, TX 77002-5013

RE: The tariff classification of liner hangers from an unknown country

Dear Ms. Ladner:

In your letter dated October 1, 2007 on behalf of Baker Oil Tools you requested a tariff classification ruling.

Liner hangers are equipment used during the drilling process of oil and gas wells. The purpose of a liner hanger is to join casing to liner. When changing from a larger inner diameter casing to a smaller inner diameter liner, a liner hanger is used to support the installation of liners. The liner hanger uses gripping mechanisms known as “slips” to attach to the inside wall of a previously installed casing. The device relies on the application of external force. The “gripping” of the casing’s inside wall cannot be initiated without the application of external differential pressure/force. The slips on the liner hanger can be activated either hydraulically or mechanically. The body of a liner hanger is manufactured from either alloy steel or non-alloy steel. Liner hangers come in a range of sizes and specifications to suite a variety of completion conditions.

You suggest classification in subheading 8431.43.8060, Harmonized Tariff Schedule of the United States (HTSUS), as parts of drilling machinery. Liner hangers are not parts of drilling machinery per se but are components of the well completion process and as such will be classified elsewhere than in subheading 8431. You cite NY ruling I88206 as supporting your position. The cited ruling dealt with classification of an article identified as a “crossover sub”. Subs are specifically included in heading 8431 by the Explanatory Notes (“EN”) and are part of the drilling process. Therefore, that ruling would not apply to this product and is inapposite.

Machinery and mechanical appliances of heading 8479 perform “individual functions” and are NOT (1) excluded from chapter 84 by any section or chapter notes nor (2) covered more specifically by any heading of chapter 84 or other heading in the HTSUS. See EN 84.79. While differential pressure/force is applied externally, the liner hangers are mechanical devices that perform their function independently of any other machine or device.

The applicable subheading for the linear hangers will be 8479.89.9850, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other Oil and gas field wireline and downhole equipment. The general rate of duty will be 2.5 percent ad valorem.

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 Patricia O’Donnell at 646-733-3011.

Sincerely,

Robert B. Swierupski
Director,

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