The tariff classification of bend limiting devices from the United Kingdom

N096398 March 16, 2010 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3926.90.9980 Mr. Patrick Fazzone Butzel Long Tighe Patton PLLC Suite 300 1747 Pennsylvania Avenue NW Washington, DC 20006 RE: The tariff classification of bend limiting devices from the United Kingdom Dear Mr. Fazzone: In your letter dated March 3, 2010, on behalf of Trelleborg Offshore US, Inc., you requested a tariff classification ruling. Descriptive literature on bend limiting devices was included with your request. The devices include bend stiffeners and bend restrictors molded from polyurethane plastic designed to be assembled over a flexible pipeline, cable, umbilical or similar component in a riser system in offshore petroleum and natural gas production. The devices protect the conduits from damage due to over-bending and fatigue. The bend stiffeners react to the force of the bending induced by wave motion or movement of the flexible riser component. The stiffeners are available in two different types. Dynamic bend stiffeners are used to protect flexible risers in long-term applications. Static bend stiffeners are used primarily for over-bend protection during riser installation. Both dynamic and static bend stiffeners are assembled over the flexible pipeline, cable or other component and cannot be removed once in place. The bend restrictor is a bend limiter used with flexible conduit connected between a surface oil or natural gas drilling or production platform and a rigid subsea structure such as a riser base or wellhead. The bend restrictor is comprised of several interlocking elements which, when assembled, for a string of elements similar to a spine or vertebrae. Each of the elements in the bend restrictor is manufactured as two halves which are bolted together. The string is then assembled onto the pipeline, cable or other riser component. Unlike a bend stiffener, the bend restrictor can be removed or replaced without disconnecting the pipeline. The applicable subheading for the bend stiffeners and bend restrictors will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 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 Joan Mazzola at (646) 733-3023. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division