The tariff classification of rig mats from Canada

N244015 August 9, 2013 CLA-2-44:OT:RR:NC:2:230 CATEGORY: Classification TARIFF NO.: 4421.90.9780 Mr. Cris Ballard Raven Oilfield Rentals Box 6238 10426 Clairmont Frontage Road Fort St. John, BC V1J4H7 CANADA RE: The tariff classification of rig mats from Canada Dear Mr. Ballard: In your letter, dated July 12, 2013, you requested a tariff classification ruling. Product information and photographs were submitted for our review. The item is a rig mat measuring 20 or 40 feet in length, 8 feet wide, and 6 inches thick. The mat is constructed of a welded steel framework that holds many sawn timbers in an edge to edge formation. This construction forms a platform upon which heavy equipment, such as drilling rigs, service rigs, or other equipment, will be supported. The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation ("GRIs"), taken in order. GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes. In the event that goods cannot be classified solely on the basis of GRI 1, and if the heading and legal notes do not otherwise require the remaining GRI will be applied, in the order of their appearance. For the instant item, neither GRI 1 nor GRI 2 is applicable. The rig mats are constructed of materials that are prima facie classifiable in different headings, i.e., wood and steel. They are therefore composite goods within the meaning of GRI 3(b). GRI 3(b) states, in pertinent part: (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. In accordance with the Explanatory Notes (ENs) for GRI 3(b), the essential character of an item may be determined by the nature of the material or component, its bulk, quantity, weight, or value, or by the role of a constituent material in relation to the use of the goods. While you note that the steel predominates in value, and it also provides the mat framework, it is the wood that provides the surface that will support the equipment. The frame appears to function mainly to hold the timbers together. Therefore, we find that it is the timbers that impart the essential character of the mats. The applicable subheading for the rig mats will be 4421.90.9780, HTSUS, Other articles of wood: Other: Other: Other: Other. The rate of duty will be 3.3 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 Laurel Duvall at (646) 733-3035. Sincerely, Deborah C. Marinucci Acting Director National Commodity Specialist Division