The tariff classification of junction plates, and test and flushing plates from an unknown country

N276219 July 1, 2016 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8588 Ms. Martina Maldonado Oceaneering International, Inc. 11917 FM 529 Road Houston, TX 77041 RE: The tariff classification of junction plates, and test and flushing plates from an unknown country Dear Ms. Maldonado: In your letter dated November 23, 2015, you requested a tariff classification ruling on junction plates, and test and flushing plates. In response to our request for additional information, our office received answers to our questions in your letter dated May 31, 2016. Photographs, engineering specifications and descriptive literature for the plates were submitted for our review. The items under consideration are identified as Fixed Junction Plates, Removable Junction Plates, Fixed Test and Flushing Plates, and Removable Test and Flushing Plates. The Fixed Junction Plate (also known as an inboard MQC - Multiple Quick Disconnect Plate) and the Removable Junction Plate (also known as an outboard MQC - Multiple Quick Disconnect Plate) are used in subsea oil and gas operations as hubs for transferring pressurized hydraulic or chemical fluids. The Fixed Junction Plate is mounted to a subsea structure and is outfitted with couplers to transfer fluid to other structures. You stated in your letter that “The Fixed Junction Plate is composed of a stainless steel coupler mounting plate contained inside a coated carbon steel housing. The coupler mounting plate contains a number of cylindrical openings that are typically populated with stainless steel couplers, which are welded to stainless steel tubing.” The Removable Junction Plate is attached to the end of a Hydraulic Flying Lead or Umbilical and is mounted to a steel frame. It is outfitted with couplers to transfer fluid. You indicated that the “The Removable Junction Plate is composed of a stainless steel coupler mounting plate contained inside a coated stainless steel shroud. The coupler mounting plate contains a number of cylindrical openings that are typically populated with stainless steel couplers, which are welded to stainless steel tubing or attached to hoses in the flying lead.” The junction plates do not directly connect to the Hydraulic Power Unit and will serve as conduits for fluids originating from the HPU through an Umbilical Termination and an Umbilical which is connected to a junction plate that is later attached to an Umbilical Termination Assembly. The Fixed Test and Flushing Plates, and the Removable Test and Flushing Plates are used in oil and gas operations as a means of pressure-testing various junction plates. The Fixed Test and Flushing Plates, and the Removable Test and Flushing Plates are composed of stainless steel coupler mounting plates, which contain a number of cylindrical openings that are populated with stainless steel couplers, which are welded to test fittings that attach to a hydraulic power unit. The Fixed Test and Flushing Plates, and the Removable Test and Flushing Plate utilize latch mechanisms and alignment features to mate to junction plates. The plates do not have any measuring devices and include a hydraulic fitting welded on the end of each coupler that is used to attach a pressure hose. All of the hoses and measuring devices for testing are not provided with the plates. You suggested classification for the Fixed Junction Plates, Removable Junction Plates, Fixed Test and Flushing Plates, and Removable Test and Flushing Plates under heading 8412, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other engines and motors, and parts thereof. However, it is a well-established rule that a part of an article is something necessary to the completion of that article. It is an integral, constituent or component part without which the article to which it is to be joined could not function as such article. Clipper Belt Lacer Co., Inc. v. United States, 14 CIT 146 (1990). Taking in consideration that the Hydraulic Power Unit does not depend on the plates to function, it is the opinion of this office, that the plates under consideration cannot fall under the purview of heading 8412, HTSUS. Therefore, the Fixed Junction Plates, Removable Junction Plates, Fixed Test and Flushing Plates, and Removable Test and Flushing Plates are classifiable under heading 7326, HTSUS, which provides for other articles of iron or steel, because they are not more specifically provided for elsewhere in the tariff. The applicable subheading for the Fixed Junction Plates, Removable Junction Plates, Fixed Test and Flushing Plates, and Removable Test and Flushing Plates will be 7326.90.8588, HTSUS, which provides for other articles of iron or steel, other…other. The rate of duty will be 2.9 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 https://hts.usitc.gov/current. 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 Ann Taub at ann.taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division