Internal Advice 23/94; Longbody Transition Adapter, Pipe Fitting, Gland With Rubber Gasket for Connecting Pipes and Tubes and Pipes and Valves; Ductile Base Metal Fitting for Repairing Pipelines; Chapter 73, Additional U.S. Note 1, Heading 7307 Dear Sir:
Active· CBP ruling HQ 956856· Issued 1994-11-09
Ruling text
HQ 956856
NOVEMBER 9, 1994
CLA-2:CO:R:C:M 956856 JAS
CATEGORY: Classification
TARIFF NO.: 7307.19.30
District Director of Customs
P.O. Box 619050
DFW Airport
Dallas/Ft. Worth, TX 75261-0950
RE: Internal Advice 23/94; Longbody Transition Adapter, Pipe
Fitting, Gland With Rubber Gasket for Connecting Pipes
and Tubes and Pipes and Valves; Ductile Base Metal Fitting
for Repairing Pipelines; Chapter 73, Additional U.S. Note 1,
Heading 7307
Dear Sir:
With your memorandum (CLA-1-D:C SS), dated April 1, 1994,
you forwarded a letter from counsel, dated January 20, 1994,
initiating this request for internal advice on the classification
of certain base metal tube and pipe fittings from China.
Photographs were submitted.
FACTS:
The merchandise in issue is the longbody transition adapter,
model 3522, an assembly consisting of a cast iron gland, formed
rubber gasket and nuts and bolts. It functions as a repair
fitting designed to facilitate replacement of valves in existing
pipelines by connecting two pipe ends together or a tube or pipe
end to a valve. The adapter contains, by weight, 3 to 4 percent
carbon and between 0.04 to 0.07 percent magnesium. The gland is
not threaded and has flanges cast into the body at both ends,
drilled to accept bolts secured with nuts. There is no
indication the nuts and bolts are a part of this inquiry.
The internal advice applicant proposes to classify these
devices in subheading 7307.19.30, Harmonized Tariff Schedule of
the United States (HTSUS), as other ductile cast fittings, of
iron or steel. - 2 -
The provisions under consideration are as follows:
4016 Other articles of vulcanized rubber other
than hard rubber:
4016.93 Gaskets, washers and other seals:
4016.93.50 Other...3.5 percent
* * * *
7307 Tube or pipe fittings (for example,
couplings, elbows, sleeves), of iron or
steel:
Cast fittings:
7307.11.00 Of nonmalleable cast iron
...4.8 percent ad valorem
7307.19 Other:
7307.19.30 Ductile fittings...6.2 percent
7307.19.90 Other...6.2 percent
ISSUE:
Whether the longbody transition adapter is a tube or pipe
fitting of iron or steel; whether it is a ductile fitting.
LAW AND ANALYSIS:
Merchandise is classifiable under the Harmonized Tariff
Schedule of the United States (HTSUS) in accordance with the
General Rules of Interpretation (GRIs). GRI 1 states in part
that for legal purposes, classification shall be determined
according to the terms of the headings and any relative section
or chapter notes, and provided the headings or notes do not
require otherwise, according to GRIs 2 through 6.
GRI 3(b) states in part that composite goods consisting of
two or more components which cannot be classified by reference to
Rule 3(a) shall be classified as if consisting of that component
which gives the good its essential character.
The Harmonized Commodity Description And Coding System
Explanatory Notes (ENs) constitute the Customs Cooperation
Council's official interpretation of the Harmonized System.
While not legally binding on the contracting parties, and
therefore not dispositive, the ENs provide a commentary on the - 3 -
scope of each heading of the Harmonized System and are thus
useful in ascertaining the classification of merchandise under
the System. Customs believes the notes should always be
consulted. See T.D. 89-80, Fed. Reg. 35127, 35128 (Aug. 23,
1989).
The longbody transition adapter is a composite good
consisting of a metal gland and a rubber gasket secured by nuts
and bolts. The factor or factors which determine essential
character will vary with the goods. It may, for example, be the
nature of the component, its bulk, quantity, weight or value, or
its role in relation to the use of the good. The model 3522
transition adapter has a male plain (unthreaded) end that is
inserted into the wider (female) bell end of a replacement valve
and becomes a part of the piping system itself. The other end
incorporates the rubber gasket and completes the connection to a
length of pipe to produce a watertight seal. The nature of the
merchandise makes it apparent that it is the metal gland which
makes the actual connection between tube or pipe sections or
between a valve and a tube or pipe section, with the gasket
serving to make the connection more secure. We conclude it is
the metal gland that imparts the essential character to the good.
The longbody transition adapter is to be classified as if
consisting only of the base metal gland.
Relevant ENs at p. 1019 state that heading 73.07 includes
fittings of iron or steel mainly used for connecting the bores of
two tubes together, or for connecting a tube to some other
apparatus, or for closing the tube aperture. The heading does
not cover articles used for installing pipes and tubes but which
do not form an integral part of the bore. The connection can be
obtained by screwing in the case of steel threaded fittings, by
welding, or by contact, when using removable steel fittings. The
longbody transition adapter meets the description for fittings of
heading 7307. In accordance with Chapter 73, Additional U.S.
Note 2, HTSUS, the adapter is within the expression "ductile
fittings" for purposes of subheading 7307.19.30.
HOLDING:
Under the authority of GRI 3(b), the longbody transition
adapter model 3522 is a tube or pipe fitting of heading 7307. It
is classifiable in subheading 7307.19.30 as a ductile cast
fitting. This decision has no application to any antidumping
duty proceedings relating to similar merchandise.
You should mail this decision to the internal advice
applicant, through counsel, no later than 60 days from the date
of this letter. On that date the Office of Regulations and
Rulings will take steps to make the decision available to Customs - 4 -
personnel via the Customs Rulings Module in ACS and to the public
via the Diskette Subscription Service, the Freedom of Information
Act, and other public access channels.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 956856, retrieved 2026-10-12T05:29:48Z, republished verbatim. This digest is informational; only CBP issues binding rulings.