The tariff classification of a Riser Turret Module from the Netherlands

N241320 May 28, 2013 CLA-2-84:OT:RR:NC:1:104 CATEGORY: Classification TARIFF NO.: 8479.89.9899 Ms. Leah Ellis JAS Forwarding USA, Inc. 5676 N. Sam Houston Pkwy. Bldg. 4, Ste. 100 Houston, TX 77032 RE: The tariff classification of a Riser Turret Module from the Netherlands Dear Ms. Ellis: In your letter dated April 8, 2013 on behalf of AMEC Oil & Gas Inc., you requested a tariff classification ruling. The Riser Turret Module (“RTM”) is designed to be positioned on the starboard side of a Marine Well Containment System (“MWCS”) Vessel (“MCV”) used for offshore drilling. The turret system, located forward of mid-ship, will be supported from the main deck extending approximately 14 meters beyond the side of the vessel. The RTM features an automatic hydraulic powered drive system which prevents winding up of the production and umbilical risers during the MCV operations. A disconnectable turret buoy is locked inside the turret structure. The RTM turret system allows the MCV to weathervane around its operating circle while maintaining production through the production riser. Electrically driven axial piston design pumps are used to power the automatic turret drive system, the winches (when required) and the turret buoy locking system. The RTM is said to consist of the following main components: (1) outrigger structure, (2) turret structure, (3) turret buoy (disconnectable), (4) turntable structure, (5) TAS and (6) swivel stack assembly. In the event of severe weather conditions, such as a hurricane, the RTM allows the MCV to perform a controlled disconnect of the subsea flexible riser and umbilical prior to seeking shelter. If the MCV suffers a DP drive off or a total blackout, the turret buoy is automatically disconnected from the RTM with the flexible riser and umbilical still attached. Once conditions return to normal, the turret buoy is pulled back into the RTM by means of the buoy pull-in winch located on the turntable deck and locked into the turret structure. At that point the production riser and umbilical control system can be reinstated and production brought back on line. You propose classifying the Riser Turret Module in subheading 8907.90.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other vessels, including warships and lifeboats other than row boats: Other … Other”. The RTM is designed to be placed onto a floating tanker. It is not designed to sit on the seabed or float on its own and, therefore, it is not a floating structure. The RTM is a part of the MCU. However, there is no parts provision for floating structures. Thus, classification in subheading 8907.90.0090, HTSUS, would not be appropriate. The applicable subheading for the Riser Turret Module, imported complete in one shipment, will be 8479.89.9899, HTSUS, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Other machines and mechanical appliances: Other: Other … Other”. The rate of duty will be 2.5 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 http://www.usitc.gov/tata/hts/. 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 Patricia O’Donnell at (646) 733-3011. Sincerely, Thomas J. Russo Director National Commodity Specialist Division