The tariff classification of a subsea control module for oil well systems from Norway

N058877 May 7, 2009 CLA-2-84:OT:RR:E:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8412.90.9015 Mr. William Da Costa Hooper FMC Technologies, Inc. 1777 Gears Road Houston, TX 77067 RE: The tariff classification of a subsea control module for oil well systems from Norway Dear Mr. Hooper: In your letter dated April 28, 2009 you requested a tariff classification ruling. The article in question is described as a “Subsea Control Module (SCM)”, which is comprised of electronics, instrumentation and hydraulics. You indicate that the SCM serves as the key component of the electric-hydraulic system used to control the operation of subsea “trees” used in oil production. The “trees” are essentially an assembly of valves and actuators mounted onto a subsea well head to allow for control over the flow of well fluids. The SCM is connected to the topside production system by control umblicals. The applicable subheading for the SCM will be 8412.90.9015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other parts of other hydraulic power engines and motors. The rate of duty is free. 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 Kenneth T. Brock at (646) 733-3009. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division