The tariff classification of funny pipe flex assemblies from Mexico

N170163 June 15, 2011 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3917.33.0000 Mr. Eugene Zakharenko The Toro Company 8111 Lyndale Avenue South Bloomington, MN 55420 RE: The tariff classification of funny pipe flex assemblies from Mexico Dear Mr. Zakharenko: In your letter dated May 17, 2011, you requested a tariff classification ruling. The imported products are identified as funny pipe 8” flex assemblies, models 53784 and 53785. A sample of model 53784 was included with your request. The flex assemblies are extension tubes with fittings used to connect PVC pipe to a sprinkler head. They are used when positioning, replacing and relocating sprinkler heads. The assemblies consist of four components that are joined together in Mexico: a non-reinforced 8 inch extension tube, two non-threaded elbows and one threaded elbow. The 8 inch extension tube is made in the United States. The threaded elbow, which is the most expensive component in the assembly, is made in Taiwan. For model 53784 the two unthreaded elbows are made in the United States. For model 53785 one unthreaded elbow is made in Mexico and one unthreaded elbow is made in the United States. In Mexico the two unthreaded elbows are permanently attached to the extension tube, one on either side. The threaded elbow is fastened into one of the unthreaded elbows. The processing in Mexico transforms the components into a flex assembly that is dedicated for use in a sprinkler system. The elbows, and the threaded elbow in particular, are essential components that allow the assembly to perform its intended function to change the direction of the water flow. Mexico is considered to be the country of origin. The applicable subheading for the funny pipe flex assemblies, models 53784 and 53785, will be 3917.33.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: other tubes, pipes and hoses: other, not reinforced or otherwise combined with other materials, with fittings. The general rate of duty will be 3.1 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