Receipt of Domestic Interested Party Petition Concerning the Tariff Classification of a Steel Tube Fitting, 6880-6882 [2016-02555]
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6880
Federal Register / Vol. 81, No. 26 / Tuesday, February 9, 2016 / Notices
On behalf of the Alaska
Regional Response Team (ARRT), the
U.S. Coast Guard (USCG) announces
establishment of a more inclusive,
comprehensive, and conservative
dispersant use policy that includes a
preauthorization area and an enhanced
protocol for use of chemical dispersant
during responses to spills of crude oil in
certain waters offshore of Alaska.
Federal regulations covering certain
vessel response plans require
development of defined dispersant
response capabilities when such vessels
are operating in waters where dispersant
use preauthorization agreements exist.
DATES: Plan holders for affected vessel
response plans have 24 months from the
date of publication of this notice to
achieve compliance.
FOR FURTHER INFORMATION CONTACT: For
information about this document: From
USCG: call or email Mark Everett,
Incident Management & Preparedness
Advisor, Seventeenth Coast Guard
District, Juneau, AK; telephone (907)
463–2804; email Mark.Everett@uscg.mil;
From Environmental Protection
Agency (EPA): call or email Chris Field,
Program Manager, Emergency
Management Program (EPA Region 10);
telephone (206) 553–1674; email
Field.Chris@epa.gov;
For the State of Alaska: call or email
Gary Folley, Program Manager,
Prevention, Preparedness & Response
Program, Division of Spill Prevention &
Response, Alaska Department of
Environmental Conservation; telephone
(907) 262–3411; email gary.folley@
alaska.gov.
SUPPLEMENTARY INFORMATION:
SUMMARY:
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Public Participation and Comments
Because this notice is nonrulemaking, no public participation or
comments are being taken. Questions
can be directed to any person named in
the FOR FURTHER INFORMATION CONTACT
section, above.
Discussion
The Alaska Regional Response Team
(ARRT) is one of 13 interagency,
intergovernmental groups responsible
under the National Oil and Hazardous
Substances Pollution Contingency Plan
(a.k.a. National Contingency Plan or
NCP) at 40 CFR part 300 for regional
planning, including policy
development, and coordination of
preparedness and response actions
related to discharges of oil and releases
of hazardous materials and other
pollutants and contaminants into the
environment. The ARRT’s
responsibilities include development of
policies regarding the preauthorization
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of certain alternative (non-mechanical)
countermeasures, including chemical
dispersants, used in oil spill response
operations.
Preauthorization for use of
dispersants has not existed in the
Alaska region since September 2008.
This new policy change will allow for
industry to develop a reliable, regulated
dispersant use capability to be available
to mitigate—if directed by the Federal
On Scene Coordinator—large crude oil
spills more readily. However, extensive
government, tribal, and other
stakeholder notifications would be
required before use.
Following a multi-year collaborative
effort among governmental agencies as
described in the NCP at 40 CFR 300.910,
the ARRT signed a new Dispersant Use
Plan for Alaska (Appendix I, Annex F,
Alaska Federal/State Preparedness Plan
for Response to Oil & Hazardous
Substance Discharges/Releases [Unified
Plan]) on January 27, 2016. This
document includes, among other things,
an updated protocol for use and
monitoring of chemical dispersants in
undesignated areas on a case-by-case
basis and a preauthorization plan for
use and monitoring of chemical
dispersants on spills from tank vessels
carrying crude oil as cargo during noninnocent passage through certain areas
north and south of the Aleutian Island
chain and the northern Gulf of Alaska.
The Dispersant Use Plan for Alaska may
be found at www.alaskarrt.org.
U.S. Coast Guard enforcement of the
requirements of 33 CFR 154.1035 and
1045 and 33 CFR 155.1035, and 1050
depends upon existence of a dispersant
preauthorization plan (including a
preauthorization area) which complies
with the requirements of the NCP,
specifically at 40 CFR 300.910.
Enforcement of the preauthorization
area compliance requirements will take
effect 24 months after publication of this
notice to allow plan holders time to
achieve compliance.
Development of the Dispersant Use
Plan for Alaska included compliance
with the consultation (with National
Marine Fisheries Service and U.S. Fish
& Wildlife Service) requirements of
section 7 of the Endangered Species Act
(ESA), Essential Fish Habitat (EFH)
analysis required by the MagnussonStevens Fisheries Conservation and
Management Act, consideration of the
requirements of the Marine Mammal
Protection Act (MMPA), outreach to
affected communities and stakeholder
groups, compliance with State of Alaska
public notice requirements, and
consultation with federally-recognized
tribes as required by Executive Order
13175. Implementation of the new
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policy includes a 24-month timeline for
development of dispersant areas to be
avoided within geographic subareas
covered by the preauthorization area. It
also includes industry establishing
sufficient dispersant capability in
locales to be available for potential
authorization for use by the Federal On
Scene Coordinator during a spill
response. Failure to establish dispersant
areas to be avoided within geographic
subareas covered by the
preauthorization area will result in the
entire geographic subarea reverting to
the case-by-case dispersant use protocol
used in undesignated areas until such
time as dispersant use avoidance areas
are developed.
This notice is issued under authority
of the Oil Pollution Act of 1990 and
Executive Order 12777.
Dated: January 28, 2016.
M.L. Everett,
Incident Management & Preparedness
Advisor, U.S. Coast Guard District Seventeen.
[FR Doc. 2016–02559 Filed 2–8–16; 8:45 am]
BILLING CODE 9110–04–P
DEPARTMENT OF HOMELAND
SECURITY
U.S. Customs and Border Protection
[USCBP–2016–0007]
Receipt of Domestic Interested Party
Petition Concerning the Tariff
Classification of a Steel Tube Fitting
U.S. Customs and Border
Protection, Department of Homeland
Security.
ACTION: Notice; solicitation of
comments.
AGENCY:
U.S. Customs and Border
Protection (CBP) has received a petition
submitted on behalf of a domestic
interested party requesting the
reclassification under the Harmonized
Tariff Schedule of the United States
(HTSUS) of a steel tube fitting from
Taiwan. CBP classified the steel tube
fitting under subheading 7307.99.50,
HTSUS, which provides for: ‘‘Tube or
pipe fittings (for example, couplings,
elbows, sleeves), of iron or steel: Other:
Other: Other.’’ The 2015 column one,
general rate of duty is 4.3 percent ad
valorem. Petitioner contends that the
proper classification for the steel tube
fitting is under subheading 8412.90.90,
HTSUS, which provides for: ‘‘Other
engines and motors, and parts thereof:
Parts: Other.’’ Petitioner asserts that
some of its competitors are classifying
all or a substantial portion of similar
fittings as parts of hydraulic systems,
under subheading 8412.90.90, HTSUS,
SUMMARY:
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Federal Register / Vol. 81, No. 26 / Tuesday, February 9, 2016 / Notices
which is duty free, thus placing
Petitioner at a competitive disadvantage.
This document invites comments with
regard to the correctness of the current
classification.
DATES: Comments must be received on
or before April 11, 2016.
ADDRESSES: You may submit comments,
identified by docket number, by one of
the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments
via docket number USCBP–2016–0007.
• Mail: Trade and Commercial
Regulations Branch, Regulations and
Rulings, Office of International Trade,
Customs and Border Protection, 90 K St.
NE., 10th Floor, Washington, DC 20229–
1177.
Instructions: All submissions received
must include the agency name and
docket number for this notice of
domestic interested party petition
concerning the tariff classification of
steel tube fittings. All comments
received will be posted without change
to https://www.regulations.gov, including
any personal information provided.
Docket: For access to the docket to
read background documents, exhibits,
or comments received, go to https://
www.regulations.gov. Submitted
comments may also be inspected during
regular business days between the hours
of 9 a.m. and 4:30 p.m., at Trade and
Commercial Regulations Branch,
Regulations and Rulings, Office of
International Trade, Customs and
Border Protection, 90 K Street NE., 10th
Floor, Washington, DC. Arrangements to
inspect submitted comments should be
made in advance by calling Joseph
Clark, Trade and Commercial
Regulations Branch, at (202) 325–0118.
Please note that any submitted
comments that CBP receives by mail
will be posted on the above-referenced
docket for the public’s convenience.
FOR FURTHER INFORMATION CONTACT:
Dwayne Rawlings, Tariff Classification
and Marking Branch, Regulations and
Rulings, Office of International Trade,
Customs and Border Protection, at (202)
325–0092.
SUPPLEMENTARY INFORMATION:
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Background
A petition has been filed under
section 516 of the Tariff Act of 1930, as
amended (19 U.S.C. 1516), on behalf of
Brennan Industries, Inc. (‘‘Petitioner’’),
which manufactures various hydraulic
connectors, fittings and adapters in
Solon, Ohio. Brennan meets all of the
requirements of a domestic interested
party set forth in 19 U.S.C. 1516(a)(2)
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Jkt 238001
and section 175.3(a) in Title 19 of the
Code of Federal Regulations (CFR).
In New York Ruling (NY) E83408,
dated July 8, 1999, a steel tube fitting
from Taiwan is described as a ‘‘cold
forged nonalloy steel male threaded
connector body having a center hex nut,
one flare tube end and one male pipe
end. These tube fittings connect a piece
of rigid tubing to a valve, manifold or
another piece of rigid tubing in a
hydraulic system.’’ CBP classified the
steel tube fitting in subheading
7307.99.50, Harmonized Tariff Schedule
of the United States (HTSUS), as a tube
or pipe fitting of iron or steel, other,
other, other. Petitioner contends that the
proper classification for the fitting is
subheading 8412.90.90, HTSUS, which
covers ‘‘Other engines and motors, and
parts thereof: Parts: Other.’’ In 1999, the
column one, general rate of duty for
subheading 7307.99.50, HTSUS, was 4.3
percent ad valorem, and for heading
8412, HTSUS, it was ‘‘Free’’ (the current
duty rates are respectively 4.3% ad
valorem and ‘‘Free’’).
Classification under the HTSUS is
made in accordance with the General
Rules of Interpretation (‘‘GRIs’’). GRI 1
provides that the classification of goods
shall be determined according to the
terms of the headings of the tariff
schedule and any relative section or
chapter notes. In the event that the
goods cannot be classified solely on the
basis of GRI 1, and if the headings and
legal notes do not otherwise require, the
remaining GRIs 2 through 6 may be
applied, in numerical order.
The Harmonized Commodity
Description and Coding System
Explanatory Notes (ENs) constitute the
official interpretation of the Harmonized
System at the international level. While
not legally binding on the contracting
parties and, therefore, not dispositive,
the ENs provide a commentary on the
scope of each heading of the
Harmonized System and are thus useful
in ascertaining the classification of
merchandise under the system. CBP’s
position is that the ENs should always
be consulted. See Treasury Decision
(T.D.) 89–80, 54 FR 35127, 35128 (Aug.
23, 1989).
The Petitioner’s Views
Petitioner contends that the proper
classification for the fitting is
subheading 8412.90.90, HTSUS, which
covers ‘‘Other engines and motors, and
parts thereof: Parts: Other.’’ Petitioner
notes that the ENs for Section XV,
HTSUS, (which covers heading 7307,
HTSUS), make clear that Section XV,
HTSUS, does not cover ‘‘[a]rticles of
Section XVI (machinery, mechanical
appliances and electrical goods, which
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6881
include hydraulic system parts).’’ See
EN 1(f) to Section XV. Section XVI,
HTSUS, covers heading 8412, HTSUS.
Petitioner also recognizes that Legal
Note 1(g) to Section XVI excludes
certain products from Section XVI
coverage, including, inter alia, parts of
general use, as defined in Note 2 to
Section XV, of base metal (section XV),
or similar goods of plastics (chapter 39).
See also EN 1(g) to Section XVI (‘‘parts
of general use’’ is defined throughout
the tariff schedule to mean, inter alia,
articles of heading 7307). Referencing
Note 2(b) to Section XVI, Petitioner then
asserts that machine parts, if suitable for
use solely or principally with a
particular kind of machine of heading
8412, are to be classified with that
machine or in heading 8409, 8431, 8448,
8466, 8473, 8503, 8522, 8529 or 8538, as
appropriate. Petitioner also cites to HQ
956743 (dated January 24, 1995), NY
I82861 (dated June 28, 2002), and NY
K89798, supra (dated October 18, 2004;
incorrectly cited by the Petitioner as NY
K89789).
Petitioner maintains the fitting of NY
E83408 is ‘‘solely imported, sold and
specifically designed according to
hydraulic system industry specifications
for use in assembly of particular
hydraulic engine or motor systems,’’
and is essential to the effective and safe
operation of the subassemblies and
components to which they are parts. As
such, according to Petitioner, it is
classifiable in subheading 8412.90.90,
HTSUS, which specifically covers
‘‘other hydraulic engine and motor
parts.’’ Petitioner also contends that
CBP’s classification is incorrect because
the fitting consists of more than one
material or substance, thus implicating
GRI 2(b) and GRI 3. Petitioner proceeds
to reason that the fitting is prima facie
classifiable as both a ‘‘tube and pipe
fitting’’ of heading 7307, HTSUS, and an
‘‘other hydraulic engine or motor part’’
of heading 8412, HTSUS, and, therefore,
GRI 3 is applicable. Petitioner then
reasons that GRI 3(a) cannot determine
classification of the fitting because the
competing headings are equally specific,
and GRI 3(b) is inapplicable as well
because the fitting’s essential character
cannot be determined. Therefore,
applying GRI 3(c), Petitioner concludes
that heading 8412, HTSUS, is the proper
heading because it is last in numerical
order behind heading 7307, HTSUS.
Analysis Used by CBP in Prior Ruling
In the ruling that is the subject of this
petition, CBP held that a cold-forged,
non-alloy, steel tube fitting that
connects rigid tubing to valves,
manifolds or other pieces of rigid tubing
in a hydraulic system is classified in
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6882
Federal Register / Vol. 81, No. 26 / Tuesday, February 9, 2016 / Notices
subheading 7307.99.50, HTSUS, as
other tube or pipe fitting (for example,
couplings, elbows, sleeves), of iron or
steel. It is CBP’s position that the subject
fitting is a part of general use that can
connect tubes and pipes, and is thus
classified under heading 7307, HTSUS,
by application of GRI 1 and the
exclusionary effect of Legal Note 1(g) to
Section XVI. In order for classification
by application of GRI 3 to be
appropriate, a good must be unable to be
classified by application of GRIs 1 or 2,
and the good must be prima facie
classifiable in two or more headings. In
this instance, goods of heading 7307,
HTSUS, are explicitly excluded from
heading 8412, HTSUS, by application of
Legal Note 1(g) to Section XVI.
Therefore, GRI 3 is not applicable.
Historically, CBP has recognized that,
for tariff purposes, hoses are not
interchangeable with pipes or tubes. In
HQ 088393, dated March 26, 1991, CBP
examined the difference between hose
fittings, and tube or pipe fittings. In that
ruling, CBP first noted that the courts
have long recognized that although a
‘‘hose’’ may be considered a ‘‘tube’’ in
common meaning, they are not
interchangeable terms for tariff
purposes. Citing John V. Carr & Son,
Inc. v. United States, 76 Cust.Ct. 162,
C.D. 4652 (1976) (interpreting the
meanings of the terms ‘‘hose’’ and
‘‘pipes and tubes’’ within the context of
the Tariff Schedule of the United States
(TSUS)); see also J.E. Bernard & Co., Inc.
v. United States, 64 Cust.Ct. 425, C.D.
4029 (1970) (in comparing the TSUS
tariff terms ‘‘copper tubing’’ and
‘‘flexible metal tubing,’’ the court
expressed the principle that quite often
articles that literally appear to respond
to the common meaning of a tariff term
are not the articles classified in a tariff
sense); R.J. Saunders & Co., Inc. v.
United States, 49 C.C.P.A. 87, C.A.D.
801 (1962). Thus, under the TSUS, CBP
consistently held that hose fittings are
not properly classifiable under the
TSUS provision for pipe and tube
fittings. See C.I.E. 953/63 (July 2, 1963),
C.I.E. 1684/65 (October 18, 1965), TC
465.251 M (June 18, 1968), TC 426.89
AS (November 27, 1968), MFG 423.371
G (September 8, 1970), and HQ 064538
(April 17, 1980). While prior TSUS
cases are not dispositive,
‘‘[n]evertheless, on a case-by-case basis
prior decisions should be considered
instructive in interpreting the HTSUS,
particularly where the nomenclature
previously interpreted in those
decisions remains unchanged and no
dissimilar interpretation is required by
the text of the HTSUS.’’ H.R. Conf. Rep.
No. 100–576, at 549–50 (1988),
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17:54 Feb 08, 2016
Jkt 238001
reprinted in 1988 U.S.C.C.A.N. 1547,
1582–83; see also NY 870421, dated
February 7, 1992.
The text of heading 7307, HTSUS,
provides for ‘‘tube or pipe fittings,’’
which is similar to the TSUS text in the
cases discussed above (‘‘pipe and tube
fittings,’’ heading 613, TSUS). Thus,
with regard to the competing HTSUS
provisions at issue, CBP’s position is
that if an iron or steel fitting is a part
of general use and is designed in such
a manner where it can be used in
conjunction with tubes or pipes, or
tubes, pipes and hoses, that fitting is
classified in heading 7307. See NY
K87518, dated July 21, 2004; see also
NY H87517, dated February 20, 2002.
However, and again with regard to the
competing headings at issue, if such
fittings meet the terms of Note 2 to
Section XVI and are considered to be
parts of hydraulic systems, such as hose
fittings (as opposed to ‘‘parts of general
use’’ of heading 7307, HTSUS), they are
classified in heading 8412, HTSUS. See
NY K89798, dated October 18, 2004; NY
N006172, dated February 28, 2007; NY
H82321, dated June 25, 2001; NY
N242950, dated June 26, 2013; see also
HQ 956743, dated January 24, 1995
(stating the general principle).
CBP concludes that the subject fittings
are parts of general use that can connect
tubes and pipes, and are thus classified
under heading 7307, HTSUS, by
application of GRI 1 and the
exclusionary effect of Legal Note 1(g) to
Section XVI. Finally, with regard to
Petitioner’s argument that GRI 3 is
applicable, in order for classification by
application of GRI 3 to be appropriate,
a good must be unable to be classified
by application of GRIs 1 or 2, and the
good must be prima facie classifiable in
two or more headings. In this instance,
goods of heading 7307, HTSUS, are
explicitly excluded from heading 8412,
HTSUS, by application of Legal Note
1(g) to Section XVI. Therefore, GRI 3 is
not applicable. In addition, GRI 3 does
not apply because the fittings do not
consist of more than one material or
substance.
Comments
Pursuant to section 175.21, CBP
Regulations (19 CFR 175.21), before
making a determination on this matter,
CBP invites written comments on the
petition from interested parties.
The domestic interested party petition
concerning the tariff classification of
hydraulic system fittings, as well as all
comments received in response to this
notice, will be available for public
inspection on the docket at
www.regulations.gov. Please note that
any submitted comments that CBP
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receives by mail will be posted on the
above-referenced docket for the public’s
convenience.
Authority
This notice is published in
accordance with 19 U.S.C. 1516 and
section 175.21 of the CBP Regulations
(19 CFR 175.21).
Dated: February 4, 2016.
R. Gil Kerlikowske,
Commissioner, U.S. Customs and Border
Protection.
[FR Doc. 2016–02555 Filed 2–8–16; 8:45 am]
BILLING CODE 9111–14–P
DEPARTMENT OF HOMELAND
SECURITY
U.S. Citizenship and Immigration
Services
[OMB Control Number 1615–0054]
Agency Information Collection
Activities: Notice of Naturalization
Oath Ceremony, Form Number N–445;
Extension, Without Change, of a
Currently Approved Collection
U.S. Citizenship and
Immigration Services, Department of
Homeland Security.
ACTION: 60-Day Notice.
AGENCY:
The Department of Homeland
Security (DHS), U.S. Citizenship and
Immigration (USCIS) invites the general
public and other Federal agencies to
comment upon this proposed extension
of a currently approved collection of
information. In accordance with the
Paperwork Reduction Act (PRA) of
1995, the information collection notice
is published in the Federal Register to
obtain comments regarding the nature of
the information collection, the
categories of respondents, the estimated
burden (i.e. the time, effort, and
resources used by the respondents to
respond), the estimated cost to the
respondent, and the actual information
collection instruments.
DATES: Comments are encouraged and
will be accepted for 60 days until April
11, 2016.
ADDRESSES: All submissions received
must include the OMB Control Number
1615–0054 in the subject box, the
agency name and Docket ID USCIS–
2006–0055. To avoid duplicate
submissions, please use only one of the
following methods to submit comments:
(1) Online. Submit comments via the
Federal eRulemaking Portal Web site at
https://www.regulations.gov under eDocket ID number USCIS–2006–0055;
(2) Email. Submit comments to
USCISFRComment@uscis.dhs.gov;
SUMMARY:
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Agencies
[Federal Register Volume 81, Number 26 (Tuesday, February 9, 2016)]
[Notices]
[Pages 6880-6882]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-02555]
-----------------------------------------------------------------------
DEPARTMENT OF HOMELAND SECURITY
U.S. Customs and Border Protection
[USCBP-2016-0007]
Receipt of Domestic Interested Party Petition Concerning the
Tariff Classification of a Steel Tube Fitting
AGENCY: U.S. Customs and Border Protection, Department of Homeland
Security.
ACTION: Notice; solicitation of comments.
-----------------------------------------------------------------------
SUMMARY: U.S. Customs and Border Protection (CBP) has received a
petition submitted on behalf of a domestic interested party requesting
the reclassification under the Harmonized Tariff Schedule of the United
States (HTSUS) of a steel tube fitting from Taiwan. CBP classified the
steel tube fitting under subheading 7307.99.50, HTSUS, which provides
for: ``Tube or pipe fittings (for example, couplings, elbows, sleeves),
of iron or steel: Other: Other: Other.'' The 2015 column one, general
rate of duty is 4.3 percent ad valorem. Petitioner contends that the
proper classification for the steel tube fitting is under subheading
8412.90.90, HTSUS, which provides for: ``Other engines and motors, and
parts thereof: Parts: Other.'' Petitioner asserts that some of its
competitors are classifying all or a substantial portion of similar
fittings as parts of hydraulic systems, under subheading 8412.90.90,
HTSUS,
[[Page 6881]]
which is duty free, thus placing Petitioner at a competitive
disadvantage. This document invites comments with regard to the
correctness of the current classification.
DATES: Comments must be received on or before April 11, 2016.
ADDRESSES: You may submit comments, identified by docket number, by one
of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments via docket number
USCBP-2016-0007.
Mail: Trade and Commercial Regulations Branch, Regulations
and Rulings, Office of International Trade, Customs and Border
Protection, 90 K St. NE., 10th Floor, Washington, DC 20229-1177.
Instructions: All submissions received must include the agency name
and docket number for this notice of domestic interested party petition
concerning the tariff classification of steel tube fittings. All
comments received will be posted without change to https://www.regulations.gov, including any personal information provided.
Docket: For access to the docket to read background documents,
exhibits, or comments received, go to https://www.regulations.gov.
Submitted comments may also be inspected during regular business days
between the hours of 9 a.m. and 4:30 p.m., at Trade and Commercial
Regulations Branch, Regulations and Rulings, Office of International
Trade, Customs and Border Protection, 90 K Street NE., 10th Floor,
Washington, DC. Arrangements to inspect submitted comments should be
made in advance by calling Joseph Clark, Trade and Commercial
Regulations Branch, at (202) 325-0118. Please note that any submitted
comments that CBP receives by mail will be posted on the above-
referenced docket for the public's convenience.
FOR FURTHER INFORMATION CONTACT: Dwayne Rawlings, Tariff Classification
and Marking Branch, Regulations and Rulings, Office of International
Trade, Customs and Border Protection, at (202) 325-0092.
SUPPLEMENTARY INFORMATION:
Background
A petition has been filed under section 516 of the Tariff Act of
1930, as amended (19 U.S.C. 1516), on behalf of Brennan Industries,
Inc. (``Petitioner''), which manufactures various hydraulic connectors,
fittings and adapters in Solon, Ohio. Brennan meets all of the
requirements of a domestic interested party set forth in 19 U.S.C.
1516(a)(2) and section 175.3(a) in Title 19 of the Code of Federal
Regulations (CFR).
In New York Ruling (NY) E83408, dated July 8, 1999, a steel tube
fitting from Taiwan is described as a ``cold forged nonalloy steel male
threaded connector body having a center hex nut, one flare tube end and
one male pipe end. These tube fittings connect a piece of rigid tubing
to a valve, manifold or another piece of rigid tubing in a hydraulic
system.'' CBP classified the steel tube fitting in subheading
7307.99.50, Harmonized Tariff Schedule of the United States (HTSUS), as
a tube or pipe fitting of iron or steel, other, other, other.
Petitioner contends that the proper classification for the fitting is
subheading 8412.90.90, HTSUS, which covers ``Other engines and motors,
and parts thereof: Parts: Other.'' In 1999, the column one, general
rate of duty for subheading 7307.99.50, HTSUS, was 4.3 percent ad
valorem, and for heading 8412, HTSUS, it was ``Free'' (the current duty
rates are respectively 4.3% ad valorem and ``Free'').
Classification under the HTSUS is made in accordance with the
General Rules of Interpretation (``GRIs''). GRI 1 provides that the
classification of goods shall be determined according to the terms of
the headings of the tariff schedule and any relative section or chapter
notes. In the event that the goods cannot be classified solely on the
basis of GRI 1, and if the headings and legal notes do not otherwise
require, the remaining GRIs 2 through 6 may be applied, in numerical
order.
The Harmonized Commodity Description and Coding System Explanatory
Notes (ENs) constitute the official interpretation of the Harmonized
System at the international level. While not legally binding on the
contracting parties and, therefore, not dispositive, the ENs provide a
commentary on the scope of each heading of the Harmonized System and
are thus useful in ascertaining the classification of merchandise under
the system. CBP's position is that the ENs should always be consulted.
See Treasury Decision (T.D.) 89-80, 54 FR 35127, 35128 (Aug. 23, 1989).
The Petitioner's Views
Petitioner contends that the proper classification for the fitting
is subheading 8412.90.90, HTSUS, which covers ``Other engines and
motors, and parts thereof: Parts: Other.'' Petitioner notes that the
ENs for Section XV, HTSUS, (which covers heading 7307, HTSUS), make
clear that Section XV, HTSUS, does not cover ``[a]rticles of Section
XVI (machinery, mechanical appliances and electrical goods, which
include hydraulic system parts).'' See EN 1(f) to Section XV. Section
XVI, HTSUS, covers heading 8412, HTSUS. Petitioner also recognizes that
Legal Note 1(g) to Section XVI excludes certain products from Section
XVI coverage, including, inter alia, parts of general use, as defined
in Note 2 to Section XV, of base metal (section XV), or similar goods
of plastics (chapter 39). See also EN 1(g) to Section XVI (``parts of
general use'' is defined throughout the tariff schedule to mean, inter
alia, articles of heading 7307). Referencing Note 2(b) to Section XVI,
Petitioner then asserts that machine parts, if suitable for use solely
or principally with a particular kind of machine of heading 8412, are
to be classified with that machine or in heading 8409, 8431, 8448,
8466, 8473, 8503, 8522, 8529 or 8538, as appropriate. Petitioner also
cites to HQ 956743 (dated January 24, 1995), NY I82861 (dated June 28,
2002), and NY K89798, supra (dated October 18, 2004; incorrectly cited
by the Petitioner as NY K89789).
Petitioner maintains the fitting of NY E83408 is ``solely imported,
sold and specifically designed according to hydraulic system industry
specifications for use in assembly of particular hydraulic engine or
motor systems,'' and is essential to the effective and safe operation
of the subassemblies and components to which they are parts. As such,
according to Petitioner, it is classifiable in subheading 8412.90.90,
HTSUS, which specifically covers ``other hydraulic engine and motor
parts.'' Petitioner also contends that CBP's classification is
incorrect because the fitting consists of more than one material or
substance, thus implicating GRI 2(b) and GRI 3. Petitioner proceeds to
reason that the fitting is prima facie classifiable as both a ``tube
and pipe fitting'' of heading 7307, HTSUS, and an ``other hydraulic
engine or motor part'' of heading 8412, HTSUS, and, therefore, GRI 3 is
applicable. Petitioner then reasons that GRI 3(a) cannot determine
classification of the fitting because the competing headings are
equally specific, and GRI 3(b) is inapplicable as well because the
fitting's essential character cannot be determined. Therefore, applying
GRI 3(c), Petitioner concludes that heading 8412, HTSUS, is the proper
heading because it is last in numerical order behind heading 7307,
HTSUS.
Analysis Used by CBP in Prior Ruling
In the ruling that is the subject of this petition, CBP held that a
cold-forged, non-alloy, steel tube fitting that connects rigid tubing
to valves, manifolds or other pieces of rigid tubing in a hydraulic
system is classified in
[[Page 6882]]
subheading 7307.99.50, HTSUS, as other tube or pipe fitting (for
example, couplings, elbows, sleeves), of iron or steel. It is CBP's
position that the subject fitting is a part of general use that can
connect tubes and pipes, and is thus classified under heading 7307,
HTSUS, by application of GRI 1 and the exclusionary effect of Legal
Note 1(g) to Section XVI. In order for classification by application of
GRI 3 to be appropriate, a good must be unable to be classified by
application of GRIs 1 or 2, and the good must be prima facie
classifiable in two or more headings. In this instance, goods of
heading 7307, HTSUS, are explicitly excluded from heading 8412, HTSUS,
by application of Legal Note 1(g) to Section XVI. Therefore, GRI 3 is
not applicable. Historically, CBP has recognized that, for tariff
purposes, hoses are not interchangeable with pipes or tubes. In HQ
088393, dated March 26, 1991, CBP examined the difference between hose
fittings, and tube or pipe fittings. In that ruling, CBP first noted
that the courts have long recognized that although a ``hose'' may be
considered a ``tube'' in common meaning, they are not interchangeable
terms for tariff purposes. Citing John V. Carr & Son, Inc. v. United
States, 76 Cust.Ct. 162, C.D. 4652 (1976) (interpreting the meanings of
the terms ``hose'' and ``pipes and tubes'' within the context of the
Tariff Schedule of the United States (TSUS)); see also J.E. Bernard &
Co., Inc. v. United States, 64 Cust.Ct. 425, C.D. 4029 (1970) (in
comparing the TSUS tariff terms ``copper tubing'' and ``flexible metal
tubing,'' the court expressed the principle that quite often articles
that literally appear to respond to the common meaning of a tariff term
are not the articles classified in a tariff sense); R.J. Saunders &
Co., Inc. v. United States, 49 C.C.P.A. 87, C.A.D. 801 (1962). Thus,
under the TSUS, CBP consistently held that hose fittings are not
properly classifiable under the TSUS provision for pipe and tube
fittings. See C.I.E. 953/63 (July 2, 1963), C.I.E. 1684/65 (October 18,
1965), TC 465.251 M (June 18, 1968), TC 426.89 AS (November 27, 1968),
MFG 423.371 G (September 8, 1970), and HQ 064538 (April 17, 1980).
While prior TSUS cases are not dispositive, ``[n]evertheless, on a
case-by-case basis prior decisions should be considered instructive in
interpreting the HTSUS, particularly where the nomenclature previously
interpreted in those decisions remains unchanged and no dissimilar
interpretation is required by the text of the HTSUS.'' H.R. Conf. Rep.
No. 100-576, at 549-50 (1988), reprinted in 1988 U.S.C.C.A.N. 1547,
1582-83; see also NY 870421, dated February 7, 1992.
The text of heading 7307, HTSUS, provides for ``tube or pipe
fittings,'' which is similar to the TSUS text in the cases discussed
above (``pipe and tube fittings,'' heading 613, TSUS). Thus, with
regard to the competing HTSUS provisions at issue, CBP's position is
that if an iron or steel fitting is a part of general use and is
designed in such a manner where it can be used in conjunction with
tubes or pipes, or tubes, pipes and hoses, that fitting is classified
in heading 7307. See NY K87518, dated July 21, 2004; see also NY
H87517, dated February 20, 2002.
However, and again with regard to the competing headings at issue,
if such fittings meet the terms of Note 2 to Section XVI and are
considered to be parts of hydraulic systems, such as hose fittings (as
opposed to ``parts of general use'' of heading 7307, HTSUS), they are
classified in heading 8412, HTSUS. See NY K89798, dated October 18,
2004; NY N006172, dated February 28, 2007; NY H82321, dated June 25,
2001; NY N242950, dated June 26, 2013; see also HQ 956743, dated
January 24, 1995 (stating the general principle).
CBP concludes that the subject fittings are parts of general use
that can connect tubes and pipes, and are thus classified under heading
7307, HTSUS, by application of GRI 1 and the exclusionary effect of
Legal Note 1(g) to Section XVI. Finally, with regard to Petitioner's
argument that GRI 3 is applicable, in order for classification by
application of GRI 3 to be appropriate, a good must be unable to be
classified by application of GRIs 1 or 2, and the good must be prima
facie classifiable in two or more headings. In this instance, goods of
heading 7307, HTSUS, are explicitly excluded from heading 8412, HTSUS,
by application of Legal Note 1(g) to Section XVI. Therefore, GRI 3 is
not applicable. In addition, GRI 3 does not apply because the fittings
do not consist of more than one material or substance.
Comments
Pursuant to section 175.21, CBP Regulations (19 CFR 175.21), before
making a determination on this matter, CBP invites written comments on
the petition from interested parties.
The domestic interested party petition concerning the tariff
classification of hydraulic system fittings, as well as all comments
received in response to this notice, will be available for public
inspection on the docket at www.regulations.gov. Please note that any
submitted comments that CBP receives by mail will be posted on the
above-referenced docket for the public's convenience.
Authority
This notice is published in accordance with 19 U.S.C. 1516 and
section 175.21 of the CBP Regulations (19 CFR 175.21).
Dated: February 4, 2016.
R. Gil Kerlikowske,
Commissioner, U.S. Customs and Border Protection.
[FR Doc. 2016-02555 Filed 2-8-16; 8:45 am]
BILLING CODE 9111-14-P