The tariff classification and country of origin of an Industrial Pitless unit

N363561August 12, 2026CLA-2-73:OT:RR:NC:N5:116
CATEGORY: Classification; Origin
TARIFF NO.: 7307.19.9060
Kyle O’ConnorDominion Customs Consultants1595 16th Avenue, Suite 202Richmond Hill, Canada L4B 3N9RE: The tariff classification and country of origin of an Industrial Pitless unit Dear Mr. O’Connor:In your letter dated
July 23, 2026
, you requested a tariff classification and a country of origin ruling for thepurposes of the applicability of trade remedies on behalf of your client, Boshart Industries LLC.The product under consideration is identified as a spool type Industrial Pitless unit made of type 304 caststainless steel. This composite good is comprised of a well cap, upper barrel, lift pipe assembly, dischargehousing, and spool and will be imported in an assembled condition. The discharge housing and spool form atee type pipe fitting (pitless adapter) with three threaded openings that attach to pipe: drop pipe, upper barrel,and service line. You indicate that the discharge housing and spool creates a 90º elbow that directs the flowof water from the submersible pump into the service line below the frost line to prevent freezing. An upperbarrel extends the well casing to the surface for easy access to the well, attaches to the well cap, and providesan additional 2 ft. above ground section to prevent surface water from contaminating the well. You state thatthe Industrial Pitless unit does not contain any mechanical features at the time of importation.Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is inaccordance with the General Rules of Interpretation (GRIs). GRI 3(b) provides that mixtures, compositegoods consisting of different materials or made up of different components, and goods put up in sets for retailsale shall be classified as if they consisted of the material or component which gives them their essentialcharacter, which may be determined by the nature of the material or component, its bulk, quantity, weight orvalue, or by the role of a constituent material in relation to the use of the article. This office finds that theessential character of the Industrial Pitless unit is imparted by the discharge housing and spool (pitlessadapter) which forms a two-piece elbow that directs the flow of water throughout the unit.
You suggest classification of the Industrial Pitless unit under subheading 7307.29.0090, HTSUS, whichprovides for tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other, of stainlesssteel: other: other. We disagree. The subject fitting is made from cast stainless steel. Cast fittings are morespecifically provided for elsewhere in heading 7307, HTSUS.The applicable subheading for the Industrial Pitless unit will be 7307.19.9060, HTSUS, which provides fortube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: cast fittings: other: other:other: other: threaded. The rate of duty will be 6.2 percent ad valorem.When determining the country of origin for purposes of applying current trade remedies under Section 232,Section 301, and other duties, the substantial transformation analysis is applicable. See, e.g., HeadquartersRuling Letter H301619, dated November 6, 2018. The test for determining whether a substantialtransformation will occur is whether an article emerges from a process with a new name, character, or usedifferent from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States,681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National HandTool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).According to your submission, the discharge housing and spool (pitless adapter) of Chinese origin and wellcap are exported to Canada and joined/assembled with the upper barrel, the lift pipe, down hooks, and weldnipples that are made in Canada from raw materials sourced from various countries to produce the IndustrialPitless unit.Based on the information provided, in our view the operations performed in Canada are neither complex nordo they result in a substantial transformation. The pitless adapter and well cap are assembled with the otherparts that are already made in Canada. The final assembly operations that are performed in Canada includethe following: threading the lower housing onto the upper barrel, threading the lower nipple into the lowerhousing, threading the lift pipe into the spool, installing O-rings onto the spool, installing spool/lift assemblyinto upper barrel/lower housing assembly, installing and tighten hold down hooks, assembling the well cap,and installing the well cap on the upper barrel. The components do not lose their separate identities whenassembled into the finished product. It is the opinion of this office that the pitless adapter of Chinese originprovides the essence of the finished Industrial Pitless unit as it directs the water flow up the drop pipe and outof the discharge pipe to the service line. As such, we find that the country of origin of the Industrial Pitlessunit for the purposes of the applicability of a trade program or a trade remedy will be China.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions onthe Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.The holding set forth above applies only to the specific factual situation and merchandise description asidentified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.Additionally, we note that the material facts described in the foregoing ruling may be subject to periodicverification by CBP.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 documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, contactNational Import Specialist Neil M. Cohen at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division