The tariff classification of Smart Pipeline Intervention Gadgets from Germany

N293003 January 18, 2018 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.80.8085 Damon Pike The Pike Law Firm, P.C. 2897 N. Druid Hills Road NE Atlanta, GA 30329 RE: The tariff classification of Smart Pipeline Intervention Gadgets from Germany Dear Mr. Pike: In your letter dated December 22, 2017, on behalf of Realrona, Inc., you requested a tariff classification ruling. Your submission concerns three models of Smart Pipeline Intervention Gadgets (Smart PIGs), identified as the RoCorr UT Service, the RoCD UT-C Service, and the RoCD EMAT-C Service. The Smart PIGS, alternatively referred to as In-Line Inspection Tools, are specially designed for use in the oil and gas industry to perform inspection operations on pipelines, an operation known as “pigging.” Per the information provided, the Smart PIGs are equipped with an array of sensors and electronic tools that enable them to collect data on the condition of a pipeline. To perform an inspection, a Smart PIG is inserted into an active pipeline by means of a launching station. Once in the pipeline, the Smart PIG is propelled by the pressure-driven flow of the product in the pipeline (oil or gas), while sensors and electronics continuously capture various data on the state of the pipeline as it travels. The Smart PIGs are capable of measuring the internal structure of the pipelines through which they travel and can detect potential anomalies such as cracks, erosion, gouging, and the like. The data collected by the Smart PIGs’ sensors are stored internally and are uploaded to a computer for further analysis after the pigging operation is complete and the PIG is removed from the pipeline. The Smart PIGs at issue are specially designed to inspect the condition of the oil and gas pipelines through which they travel. The data collected by the PIGs’ sensors can identify potential faults in the pipeline, including cracks, metal loss, and other defects. In this respect the Smart PIGs perform a function similar to that of the instruments described in Harmonized System Explanatory Note (I)(A)(27) to Heading 9031. The applicable subheading for the RoCorr UT Service, the RoCD UT-C Service, and the RoCD EMAT-C Service Smart PIGs will be 9031.80.8085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other. The rate of duty will be 0.8% 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 Evan Conceicao at evan.m.conceicao@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division