The classification of pneumatic cleanout test plugs from Taiwan

N326065 June 10, 2022 CLA-2 OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8481.80.1050 Chandanie J. Gunathilake IPS Corporation 500 Distribution Parkway Collierville, Tennessee 38017 RE: The classification of pneumatic cleanout test plugs from Taiwan Dear Ms. Gunathilake: In your letter dated May 12, 2022, you requested a ruling on the classification of pneumatic cleanout test plugs. Descriptive information was provided and a sample was sent for our review. The merchandise under consideration is referred to as pneumatic cleanout test plugs, item numbers 83651 and 83661. The difference between the two item numbers is that item 83661 is packed in a bag in bulk, whereas item 83651 is individually packaged in a retail box. Both items are designed to test plumbing pipelines that are located above a cleanout tee, and mainly consist of a rubber bladder and a brass Schrader valve with a bronze valve cap. In use, the pneumatic test plug is screwed into the cleanout tee. The valve allows air to flow into the bladder, and once the water test is complete, the air is released from the bladder by manually depressing the valve. It is stated that the maximum operating pressure of the valve is 35 pounds of force per square inch (psig). The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation ("GRIs"), taken in order. General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Because the pneumatic cleanout test plug primarily consists of a rubber bladder and brass valve, both of which are classifiable under a different heading in the HTSUS, GRI 3 governs classification. GRI 3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. GRI 3(c) provides that when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in numerical order among the competing headings which equally merit consideration. With this particular merchandise no single component imparts the essential character. Therefore, in accordance with GRI 3(c), the pneumatic cleanout test plug will be classified in heading 8481, HTSUS, as it is last in numerical order in the tariff. Heading 8481, which provides for “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof.” The applicable subheading for the pneumatic cleanout test plug, item numbers 83651 and 83661, will be 8481.80.1050, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Hand operated: Of copper, Having a pressure rating under 850 kPa: Other. The rate of duty is 4 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 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. Part 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 Sandra Martinez at Sandra.Martinez@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division