The tariff classification of a perforating gun and a connector for a perforating gun from China

N297096 June 13, 2018 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688 Mr. Robert A. Saucedo SLC Technologies P.O. Box 6761 Kingwood, TX 77325 RE: The tariff classification of a perforating gun and a connector for a perforating gun from China Dear Mr Saucedo: In your letter dated May 17, 2018, you requested a tariff classification ruling on a perforating gun and a connector for a perforating gun. Photographs, engineering specifications and descriptive literature for the perforating gun and connector were submitted for our review. You have described the subject perforating gun and the connector for the perforating gun as oil field tools made of steel. The perforating gun is used to perforate holes inside the casing of an oil and gas well. The connector for the perforating gun is used to connect perforating guns together. You stated in your letter that “The name perforating guns is an oil field term used to describe a tool used to perforate holes in the casing (steel tubulars) and surrounding formation of an oil and gas well.  Perforating guns are not fire arms or weapons of any kind, they are merely a steel tube with an internal carrier that holds shaped charges that are set off electrically or with a dropped bar to put a hole in the casing or the open hole formation of an oil and gas well. The perforating guns are scalloped on the outside and have a one-time use, once the shaped charges in the carrier tube inside is setoff the perforating guns are pulled out of the oil or gas well and disposed of as scrap metal.  The perforating process is the first step in the fracture stimulating process of producing oil and gas. Water and sand are pumped under high pressure through the perforated holes in the casing and surrounding ground to break up the formation so that oil and gas can be produced through the well bore.” Please note HQ H053672 dated January 11, 2013 regarding the revocation of N012463 for the classification of a perforating gun assembly. In HQ?H053672 CBP determined that the perforating gun assembly was classified in heading 7326, Harmonized Tariff Schedule of the United States (HTSUS), as an other article of steel. The applicable subheading for the perforating gun and the connector for a perforating gun will be 7326.90.8688, 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