The tariff classification of sealing assemblies from Vietnam

N304201 May 22, 2019 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688 Ms. Cynthia Ann Benway Taco, Inc. 1160 Cranston Street Cranston, RI 02920 RE: The tariff classification of sealing assemblies from Vietnam Dear Ms. Benway: In your letter dated May 3, 2019, you requested a tariff classification ruling for sealing assemblies. Catalog pages and instruction sheets were submitted for our review. The articles under consideration are identified in your letter as CBX bladder sealing assemblies, part numbers 600-3015 and 600-3016. You stated that “These sealing assemblies are one piece, cast parts made from 4140 carbon steel and machined to our specifications. The part has a round sealing surface with a threaded shaft protruding from one side and a small boss on the opposite side, used for orienting the part during assembly into the final product.” The 600-3015 assembly measures approximately 2.32” in length, 0.875” in diameter for the threaded end, and 2.38” for the head of the assembly. The 600-3016 assembly measures approximately 2.31” in length, 0.875” in diameter for the threaded end, and 3.124” for the head of the assembly. These assemblies are used inside an expansion tank to hold the bladder in place. An expansion tank is used in a hot water heating system to control the expansion of the system water as it is heated by a typical boiler. In your request you suggested that the bladder seal assemblies are provided for in heading 7318, Harmonized Tariff Schedule of the United States (HTSUS), which provides for bolts, rivets, cotters and similar articles of iron or steel. This office disagrees. The sealing assembly is inserted through a hole in the top of a rubber bladder and a nut and washer are threaded onto that assembly, which provides a seal for the bladder and a rigid base for the support column. A slight protuberance on the head of the sealing assembly orients the bladder’s support column which is then held in place by compression. This office has determined that the sealing assembly does not function like a fastener of heading 7318. Therefore, the subject sealing assemblies would be classified under heading 7326, HTSUS, which provides for other articles of iron or steel. The applicable subheading for the CBX bladder sealing assemblies, part numbers 600-3015 and 600-3016, will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other, 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