The tariff classification of a rubber sealing collar and plastic segments from Germany and tainless steel clamping bands from China

N318784 April 29, 2021 CLA-2-40:OT:RR:NC:N1:137 CATEGORY: Classification TARIFF NO.: 3926.90.9985, 4016.93.5050, 7326.90.8688, 9903.88.03 Cindy Ingels REHAU Industries LLC 1501 Edwards Ferry Road NE Leesburg, Virginia 20176 RE: The tariff classification of a rubber sealing collar and plastic segments from Germany and tainless steel clamping bands from China Dear Ms. Ingels: In your letter dated April 7, 2021 you requested a tariff classification ruling. The sealing collar is composed of vulcanized ethylene propylene diene monomer (EPDM) rubber. The collar is injection molded in Germany and is used as the primary sealing component in a universal pipe coupling. The sealing collar provides a watertight environment for a sewer pipe repair. The plastic segments are components used in the assembly of the universal pipe coupling. Per the submitted documentation, it is manufactured from injection-molded plastic in Germany. These segments are joined around the coupling and fit in between the rubber gasket/seal and the metal clamping bands. They are intended to add stiffness, shape, and stability to the seal. The clamping bands from China are made of stainless steel by various manufacturing processes.  The subject  bands are used for tightening a universal pipe coupling.  You state that the clamping bands act as a tightening feature for the seal.  For example, if one pipe is smaller than the other, the clamping bands will allow the seal to tighten securely around both pipes.  In the condition as imported, each clamping band consists of a tightening/tensioning band that measures a maximum thickness of 0.8 mm, a strap band and strap adjuster, a turnbuckle similar to a worm gear, and a screw for the turnbuckle.   Each component is made of stainless steel.  The length and width of the tightening band, and the strap band and strap adjuster vary based on the size of the finished good.  The type 160 band has a clamping range of 160 to 200 mm and the type 250 band has a clamping range of 250 to 330 mm.  The clamping bands will be imported fully assembled. The applicable subheading for the EPDM rubber sealing collar will be 4016.93.5050, HTSUS, which provides for other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: other:other. The general rate of duty will be 2.5 percent ad valorem. As the subject plastic segments would be considered articles of plastic, and as they are not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9985, HTSUS, which provides for other articles of plastics and articles of other materials of headings 3901 to 3914: other: other: other. The general rate of duty is 5.3 percent ad valorem. The applicable subheading for the stainless steel clamping bands made in China will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other…other.  The general rate of duty will be 2.9 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7326.90.8688, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7326.90.8688, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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 the 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 EPDM rubber seal, contact National Import Specialist (NIS) Christina Allen at julie.c.allen@cbp.dhs.gov, regarding the plastic segments, contact NIS Kristopher Burton at kristopher.burton@cbp.dhs.gov and regarding the clamping bands, contact NIS Ann Taub at ann.taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division