WEBVTT 00:00:23.752 --> 00:00:27.600 ALLEN, CHRISTINA Good afternoon my name is Christina Allen. 00:00:27.600 --> 00:00:32.210 I am the national import specialist 137. 00:00:32.210 --> 00:00:37.420 I currently handle chapter 26, which covers ORS slag and ash. 00:00:38.525 --> 00:00:40.429 ALLEN, CHRISTINA Chapter 27. 00:00:41.625 --> 00:00:45.030 ALLEN, CHRISTINA Which covers mineral fuels oils and products 00:00:45.030 --> 00:00:46.150 of their distillation? 00:00:47.275 --> 00:00:50.070 ALLEN, CHRISTINA But Tumminia Substances and mineral waxes. 00:00:50.650 --> 00:00:54.150 ALLEN, CHRISTINA Hitting 3826, which covers biodiesel. 00:00:54.150 --> 00:00:59.440 ALLEN, CHRISTINA Headings 3901 to 3923, which cover polymers 00:00:59.440 --> 00:01:02.410 of primary forms and various articles of plastic. 00:01:02.410 --> 00:01:08.867 ALLEN, CHRISTINA Umm headings 40 oh one through 4010 and 4016, 00:01:08.869 --> 00:01:14.849 which covered the rubber and primary forms and articles of rubber today. 00:01:14.850 --> 00:01:18.800 I'm gonna be speaking to you about heading 3917, 00:01:18.800 --> 00:01:21.380 which covers tubes pipes and hoses. 00:01:21.380 --> 00:01:23.980 ALLEN, CHRISTINA And fittings therefore. 00:01:23.980 --> 00:01:27.780 ALLEN, CHRISTINA Of plastics, I will answer all questions 00:01:27.780 --> 00:01:29.500 at the end of the presentation. 00:01:29.500 --> 00:01:31.470 So when I open the floor for questions. 00:01:31.470 --> 00:01:33.150 You can post them in the chat box. 00:01:34.130 --> 00:01:39.560 Please understand that some scenarios are more complex and I may not be able 00:01:39.560 --> 00:01:42.160 to answer them during the presentation. 00:01:42.160 --> 00:01:46.930 But I will make note of that question and get back to you at a later time. 00:01:51.547 --> 00:01:53.840 ALLEN, CHRISTINA CBP 's mission statement is 00:01:53.840 --> 00:01:57.410 to protect the American people safeguard our borders 00:01:57.410 --> 00:02:00.530 and enhance the nation 's economic prosperity. 00:02:00.530 --> 00:02:03.730 The Office of trade mission statement is that the office 00:02:03.730 --> 00:02:08.890 of trade facilitates legitimate trade enforces US laws 00:02:08.890 --> 00:02:12.520 and protects the American economy to ensure consumer safety 00:02:12.567 --> 00:02:17.427 and to create a level playing field for American businesses. 00:02:19.550 --> 00:02:21.380 ALLEN, CHRISTINA I'm I won't read this to you, 00:02:21.380 --> 00:02:26.050 but I'll give you just a few moments to read this disclaimer slide 00:02:26.050 --> 00:02:28.340 about the information in this presentation. 00:02:40.727 --> 00:02:44.890 ALLEN, CHRISTINA Here's another disclaimer slot about our audio visual. 00:02:44.890 --> 00:02:47.810 ALLEN, CHRISTINA That everything is from public domain. 00:02:50.578 --> 00:02:54.940 ALLEN, CHRISTINA And here is the link to file an E ruling. 00:02:54.940 --> 00:02:57.340 ALLEN, CHRISTINA If you would like to file a ruling 00:02:57.340 --> 00:03:02.750 for some of your merchandise as there are complicated factors involved 00:03:02.750 --> 00:03:04.718 in customs issues. 00:03:10.400 --> 00:03:12.030 ALLEN, CHRISTINA OK, so. 00:03:14.524 --> 00:03:19.859 ALLEN, CHRISTINA Let's get started heading 3917 covers tubes pipes 00:03:19.860 --> 00:03:24.390 and hoses and fittings, therefore for example, joints elbows and flanges. 00:03:24.390 --> 00:03:27.380 ALLEN, CHRISTINA Of plastics. 00:03:32.774 --> 00:03:39.159 ALLEN, CHRISTINA Tubes and hoses is are defined by Chapter 39 legal note 8, 00:03:39.160 --> 00:03:43.990 which basically reads for the purposes of 3917 tubes pipes 00:03:43.990 --> 00:03:48.640 and hoses means hollow products whether semi manufacturers 00:03:48.640 --> 00:03:52.480 or finished products of a kind generally used for conveying conducting 00:03:52.480 --> 00:03:55.520 or distributing gas or liquid or example. 00:03:55.520 --> 00:03:57.780 A ribbed garden hose perforated tubes. 00:03:57.780 --> 00:04:01.890 ALLEN, CHRISTINA This expression also includes sausage casings, 00:04:01.890 --> 00:04:07.000 and other layflat tubing, however, except for the last mention those having 00:04:07.000 --> 00:04:08.960 an internal cross section other than. 00:04:08.960 --> 00:04:14.730 ALLEN, CHRISTINA Round Oval or rectangular and in rectangular. 00:04:14.730 --> 00:04:19.540 ALLEN, CHRISTINA The linked cannot exceed the width by one and a half times 00:04:19.540 --> 00:04:23.150 or not in the shape of a regular Polygon will not be regarded 00:04:23.150 --> 00:04:27.360 as tubes pipes and hoses but as profile shapes. 00:04:31.909 --> 00:04:37.119 ALLEN, CHRISTINA So the explanatory notes, UM breaks this. 00:04:37.120 --> 00:04:41.680 ALLEN, CHRISTINA That that no that note into like 2 sections. 00:04:41.680 --> 00:04:44.190 And although they're not dispositive explanatory. 00:04:44.190 --> 00:04:48.523 Notes are to be looked at for guidance to the proper interpretation of the HTS. 00:04:48.546 --> 00:04:52.530 ALLEN, CHRISTINA So for that explanatory note 00:04:52.530 --> 00:04:58.900 to heading 3917 they show they break, it into 2 sections. 00:04:58.900 --> 00:05:00.540 ALLEN, CHRISTINA One is the hollow products. 00:05:00.540 --> 00:05:04.880 ALLEN, CHRISTINA And the other is the sausage casings, 00:05:04.880 --> 00:05:06.680 and the other lay flat tubing. 00:05:06.680 --> 00:05:09.218 ALLEN, CHRISTINA So what that's telling us there and 00:05:09.249 --> 00:05:13.249 when you break it apart is that all those instructions 00:05:13.250 --> 00:05:15.720 about the cross section and the. 00:05:15.720 --> 00:05:20.990 ALLEN, CHRISTINA Shape of the cross section, the size of the cross section 00:05:20.990 --> 00:05:25.960 that only apply and the requirement that they be for conveying conducting 00:05:25.960 --> 00:05:30.720 and distributing gas or liquid is only for hollow products 00:05:30.720 --> 00:05:35.940 that those rules do not apply to sausage casings, or other lay flat tubing. 00:05:38.775 --> 00:05:40.968 ALLEN, CHRISTINA So, just to simplify it a little bit 00:05:42.050 --> 00:05:44.124 when you look at note 8. 00:05:44.820 --> 00:05:45.995 ALLEN, CHRISTINA Umm. 00:05:46.625 --> 00:05:49.900 ALLEN, CHRISTINA To those pipes and hoses one they must be hollow. 00:05:50.775 --> 00:05:54.160 ALLEN, CHRISTINA They must be semi manufactured or finished products. 00:05:55.200 --> 00:05:57.912 Generally, they are for conveying conducting 00:05:57.913 --> 00:05:59.840 or distributing gas or liquids. 00:05:59.840 --> 00:06:03.330 ALLEN, CHRISTINA And they have to have an internal cross section 00:06:03.330 --> 00:06:04.810 that is round. 00:06:04.810 --> 00:06:09.610 Oval rectangular if the link does not exceed one and a half times. 00:06:09.640 --> 00:06:13.340 The width or in the shape of a regular Polygon. 00:06:13.340 --> 00:06:17.380 If those hollowed products don't fit that criteria. 00:06:17.380 --> 00:06:23.250 They are considered to be profile shapes and then it covers sausage casings, 00:06:23.250 --> 00:06:28.750 and other layflat tubing and a reminder the previous criteria does not apply 00:06:28.750 --> 00:06:29.680 to sausage casings. 00:06:29.680 --> 00:06:35.070 ALLEN, CHRISTINA More lay flat tubing that I can't say that enough 00:06:35.070 --> 00:06:40.690 because that comes up quite a lot in questions and and the confusion in 00:06:40.690 --> 00:06:44.550 when it's all written in that OneNote people tend to try to overlap them. 00:06:44.550 --> 00:06:49.530 So just always remember that those rules do not apply to sausage casings, 00:06:49.553 --> 00:06:50.993 and other layflat tubing. 00:06:54.150 --> 00:06:57.579 ALLEN, CHRISTINA OK so the heading also includes fittings. 00:06:58.548 --> 00:07:02.203 ALLEN, CHRISTINA For tubes pipes and hoses if they are plastic. 00:07:03.510 --> 00:07:06.487 ALLEN, CHRISTINA Umm tubes pipes hoses and fittings, 00:07:06.488 --> 00:07:11.221 therefore can be rigid or flexible and they may be reinforced 00:07:11.222 --> 00:07:14.580 or otherwise combined with other materials. 00:07:14.580 --> 00:07:15.610 ALLEN, CHRISTINA Umm. 00:07:19.525 --> 00:07:22.060 ALLEN, CHRISTINA A thing to remember about the fittings is 00:07:22.060 --> 00:07:24.130 that we have headings that are cover. 00:07:24.130 --> 00:07:28.420 ALLEN, CHRISTINA The houses, with fittings and if it's a hose 00:07:28.420 --> 00:07:30.290 that comes intact with the fittings. 00:07:30.290 --> 00:07:34.590 We disregard the material that is used in those fittings. 00:07:36.280 --> 00:07:39.089 ALLEN, CHRISTINA The fittings only have to be plastic if they are 00:07:39.090 --> 00:07:41.000 being entered on their own. 00:07:41.000 --> 00:07:45.390 But if they come in attached to the plastic hose or tube. 00:07:45.390 --> 00:07:48.650 ALLEN, CHRISTINA The feeding just basically gets disregarded 00:07:48.650 --> 00:07:52.790 as just being a hose or a tube with fittings attached. 00:07:55.900 --> 00:07:57.740 ALLEN, CHRISTINA So the cross section. 00:07:58.899 --> 00:08:02.469 ALLEN, CHRISTINA Like I said, before the cross section has to be round. 00:08:02.470 --> 00:08:08.656 Oval rectangular if the length does not exceed one and a half times. 00:08:08.702 --> 00:08:11.759 The width and then in the shape of a regular Polygon. 00:08:14.900 --> 00:08:18.760 ALLEN, CHRISTINA Just to define in case anyone has been a while 00:08:18.760 --> 00:08:21.300 since you've taken geometry or. 00:08:22.899 --> 00:08:26.909 ALLEN, CHRISTINA A regular Polygon is one where all the sides 00:08:26.910 --> 00:08:32.470 and angles are equal like an equilateral triangle square. 00:08:32.470 --> 00:08:35.980 Pentagon hexagon heptagon Octagon. 00:08:35.980 --> 00:08:37.300 And so forth. 00:08:37.300 --> 00:08:38.090 The key thing. 00:08:38.090 --> 00:08:45.170 There is that the angles and sides have to be equal on those. 00:08:47.274 --> 00:08:51.789 ALLEN, CHRISTINA If the tubes or hoses have a more complex cross section. 00:08:53.150 --> 00:08:55.360 ALLEN, CHRISTINA Then the previous instructions, 00:08:55.360 --> 00:09:00.330 they would be considered profile shapes of heading 3916. 00:09:01.525 --> 00:09:04.270 ALLEN, CHRISTINA As long as they are not further worked. 00:09:04.270 --> 00:09:06.420 ALLEN, CHRISTINA If they're further works, 00:09:06.420 --> 00:09:10.240 then they would go in other headings in the chapter. 00:09:18.281 --> 00:09:22.100 ALLEN, CHRISTINA So now I'm just sausage casings, and on this slide. 00:09:22.100 --> 00:09:27.520 There are just some various photos to show you the different ways 00:09:27.520 --> 00:09:29.870 in which sausage casings. 00:09:31.275 --> 00:09:32.283 ALLEN, CHRISTINA Can be presented? 00:09:38.709 --> 00:09:44.829 ALLEN, CHRISTINA And so heading 39 subheading 3917 dot 10 is the heading. 00:09:44.830 --> 00:09:49.010 ALLEN, CHRISTINA Umm that ALLEN, CHRISTINA covers. 00:09:50.150 --> 00:09:50.882 ALLEN, CHRISTINA Sausage casings. 00:09:52.024 --> 00:09:54.868 ALLEN, CHRISTINA Scott sausage casings are described 00:09:54.869 --> 00:09:59.000 as artificial guts, sausage casings of hardened protein 00:09:59.000 --> 00:10:02.380 or of cellulosic plastic materials. 00:10:02.380 --> 00:10:04.450 So I know that the question. 00:10:04.450 --> 00:10:07.520 That's coming to your mind right now is what is a hardened protein 00:10:07.520 --> 00:10:08.250 and what is a cellulosic? 00:10:10.025 --> 00:10:11.150 ALLEN, CHRISTINA Plastic. 00:10:11.150 --> 00:10:14.720 ALLEN, CHRISTINA So the explanatory notes 00:10:14.720 --> 00:10:22.000 for heading 3rd heading 3913 gives us the definition of a hardened protein 00:10:22.000 --> 00:10:26.460 and basically it's that a protein is a nitrogenous compound 00:10:26.460 --> 00:10:30.820 of very high molecular weight of vegetable or animal origin. 00:10:30.820 --> 00:10:35.540 ALLEN, CHRISTINA The heading, though only covers proteins 00:10:35.540 --> 00:10:38.810 that have been chemically processed to harden them. 00:10:38.810 --> 00:10:39.910 ALLEN, CHRISTINA And. 00:10:39.910 --> 00:10:49.980 ALLEN, CHRISTINA Just for a UM additional reference headquarters 083709 00:10:49.980 --> 00:10:54.100 affirmed that nowhere in legal or explanatory notes was hardened. 00:10:54.100 --> 00:10:58.500 ALLEN, CHRISTINA Limited to main hardened only with formaldehyde 00:10:58.500 --> 00:11:04.100 and phenols so it as long as they have been chemically hardened process 00:11:04.100 --> 00:11:07.180 to harden they would be considered hardened proteins. 00:11:07.180 --> 00:11:10.690 No matter what the chemicals used to harden them would be. 00:11:10.690 --> 00:11:15.940 ALLEN, CHRISTINA Explanatory note 3912 gives us the definition 00:11:15.940 --> 00:11:20.310 of cellulosic plastics and basically cellulose 00:11:20.310 --> 00:11:25.320 is a high molecular weight carbohydrate that forms the solid structure 00:11:25.320 --> 00:11:26.380 of vegetable matter. 00:11:27.359 --> 00:11:31.499 The group also includes chemical derivatives of cellulose. 00:11:31.500 --> 00:11:35.090 ALLEN, CHRISTINA Umm and plastics that are chemically derived 00:11:35.090 --> 00:11:38.910 from cellulose generally need the addition of plasticizers. 00:11:44.905 --> 00:11:49.109 ALLEN, CHRISTINA So now we talk about layflat tubing, UM. 00:11:49.110 --> 00:11:54.780 ALLEN, CHRISTINA Because by definition, 3917 includes other 00:11:54.780 --> 00:11:58.770 which would be other than sausage casings lay flat tubing. 00:11:58.770 --> 00:12:03.830 ALLEN, CHRISTINA Excuse me so here are some examples 00:12:03.830 --> 00:12:07.310 of different ways that you see the presentation of layflat tubing. 00:12:07.310 --> 00:12:08.160 ALLEN, CHRISTINA Umm. 00:12:10.774 --> 00:12:14.999 ALLEN, CHRISTINA Layflat tubing, the definition is very straightforward 00:12:15.000 --> 00:12:20.490 and basically it is a tubing that cannot support a tubular shape 00:12:20.491 --> 00:12:25.628 and therefore lays flat so there's really nothing complicated 00:12:25.629 --> 00:12:27.330 about the definition there. 00:12:28.727 --> 00:12:30.130 ALLEN, CHRISTINA It is what it looks like. 00:12:31.025 --> 00:12:33.140 ALLEN, CHRISTINA A key thing about Layflat Tubing is 00:12:33.140 --> 00:12:37.360 that sometimes it is used as one of the steps in the manufacture 00:12:37.360 --> 00:12:42.810 of plastic bags, so you can get rolls of tubing that have adjusted it 00:12:42.810 --> 00:12:47.040 or non gusseted and then their heat sealed at intervals. 00:12:47.040 --> 00:12:49.500 Sometimes they have perforations at intervals 00:12:49.500 --> 00:12:52.020 to allow for easy tear off think 00:12:52.020 --> 00:12:56.140 about the roles of produce bags that you see in the grocery store. 00:12:56.140 --> 00:13:01.210 ALLEN, CHRISTINA Sometimes they're just to be cut to form separate bags 00:13:01.210 --> 00:13:06.420 and later cutting can include the formation and cutting of handles. 00:13:11.525 --> 00:13:14.190 ALLEN, CHRISTINA And like I said lay flat tubing frequently used 00:13:14.190 --> 00:13:15.070 for packaging. 00:13:15.070 --> 00:13:20.660 ALLEN, CHRISTINA Since Layflat Tubing is included by name 00:13:20.660 --> 00:13:24.950 in heading 3917 its function is irrelevant. 00:13:24.950 --> 00:13:30.480 So if it's lay flat, it doesn't matter if it conducts liquid or gas or not. 00:13:33.275 --> 00:13:37.500 ALLEN, CHRISTINA If he shrink tubing comes in a lay flat form, 00:13:37.500 --> 00:13:42.660 then it would be classified in 3917 and we'll talk a little bit more 00:13:42.660 --> 00:13:44.910 about heat shrink tubing later. 00:13:44.910 --> 00:13:47.520 But if it is in Lake Platform. 00:13:47.520 --> 00:13:50.130 It is classified in 3917. 00:13:52.775 --> 00:13:56.630 ALLEN, CHRISTINA So we talked about in the additional in the note 8. 00:13:56.630 --> 00:14:01.450 It says generally of the type conveying conducting or distributing gas 00:14:01.450 --> 00:14:03.020 and liquids so if the. 00:14:04.774 --> 00:14:08.119 ALLEN, CHRISTINA Tubing is not a sausage casing or lay flat, 00:14:08.120 --> 00:14:13.360 then it must be generally used for conveying conducting distributing gases 00:14:13.360 --> 00:14:14.610 or liquids. 00:14:15.525 --> 00:14:17.980 ALLEN, CHRISTINA And that's easy to understand it's like just the water hose 00:14:17.980 --> 00:14:22.670 or those type things but a thing to note is that plastic drinking straws. 00:14:22.670 --> 00:14:27.250 ALLEN, CHRISTINA Also fit the description of these type tubes. 00:14:27.250 --> 00:14:31.170 ALLEN, CHRISTINA And they are classifiable in 3917 00:14:31.170 --> 00:14:36.720 and for additional reference you can look to headquarters 952264. 00:14:43.000 --> 00:14:45.770 ALLEN, CHRISTINA So now we have electrical conduit. 00:14:47.025 --> 00:14:53.540 ALLEN, CHRISTINA It's typically a rigid PVC type conduit, it is used 00:14:53.540 --> 00:14:54.700 to protect wiring. 00:14:54.700 --> 00:15:02.810 ALLEN, CHRISTINA So, therefore, it is not of the kind that is generally used 00:15:02.810 --> 00:15:05.180 to conduct liquids or gases. 00:15:05.180 --> 00:15:08.520 So, therefore, it's not described in 3917 00:15:08.520 --> 00:15:12.490 and would be more appropriately classified in 392690. 00:15:17.320 --> 00:15:19.140 ALLEN, CHRISTINA And I told you we would talk a little bit more 00:15:19.140 --> 00:15:21.190 about heat shrink tubing. 00:15:22.199 --> 00:15:25.789 This slide applies only to the Lay Flat. 00:15:25.790 --> 00:15:30.140 ALLEN, CHRISTINA Other than lay flat heat shrink tubing, 00:15:30.140 --> 00:15:32.810 so if it's just the hollow form. 00:15:32.810 --> 00:15:35.440 ALLEN, CHRISTINA It is generally not. 00:15:35.440 --> 00:15:38.240 ALLEN, CHRISTINA For conducting liquids or gases. 00:15:38.240 --> 00:15:39.970 They are used for corrosion. 00:15:39.970 --> 00:15:45.980 They are used to seal joints to connect wires. 00:15:45.980 --> 00:15:48.970 At times protect wires. 00:15:48.970 --> 00:15:53.157 So, therefore, they will not be classified in 3917, 00:15:53.158 --> 00:15:59.090 but rather will also be in 392690, like the conduit. 00:16:01.524 --> 00:16:05.019 ALLEN, CHRISTINA Perforated tubing and hoses. 00:16:07.025 --> 00:16:09.430 ALLEN, CHRISTINA That are they are still a hose that will conduct. 00:16:09.430 --> 00:16:16.180 ALLEN, CHRISTINA Liquid you see this type of hose as irrigation drip lines, 00:16:16.180 --> 00:16:19.200 sometimes perforated water hoses. 00:16:19.200 --> 00:16:23.120 ALLEN, CHRISTINA Water does flow through those hoses 00:16:23.120 --> 00:16:27.070 and therefore they meet the definition of 39 to 17 00:16:27.070 --> 00:16:29.231 and therefore would remain classified there, 00:16:29.232 --> 00:16:30.960 even though they had do have holes. 00:16:35.250 --> 00:16:38.990 ALLEN, CHRISTINA We get quite a lot of questions about tubes versus hoses. 00:16:40.274 --> 00:16:43.899 ALLEN, CHRISTINA And we base most of our a lot of our rulings 00:16:43.900 --> 00:16:44.830 and we base our. 00:16:44.830 --> 00:16:48.810 ALLEN, CHRISTINA Categorization on John B Carr 00:16:48.810 --> 00:16:51.580 and Sun versus the United States. 00:16:51.580 --> 00:16:56.230 ALLEN, CHRISTINA In that case, the court said it is to be noted that a tube 00:16:56.230 --> 00:17:01.570 as it is known within the industry is made of a single extruded compound 00:17:01.570 --> 00:17:03.250 rather than many materials. 00:17:03.250 --> 00:17:08.390 ALLEN, CHRISTINA Which houses are made of UM specifically this is quoted 00:17:08.390 --> 00:17:14.360 in headquarters 088393 and headquarters 956743? 00:17:14.360 --> 00:17:18.460 ALLEN, CHRISTINA Basically, all that tells us 00:17:18.460 --> 00:17:23.410 that is that tubes are typically single extrusions. 00:17:23.410 --> 00:17:26.140 ALLEN, CHRISTINA Which means that they the material 00:17:26.140 --> 00:17:30.250 to make the tube the plastic is formed and then? 00:17:30.250 --> 00:17:34.489 It is pressed through a machine that then extrudes it 00:17:34.490 --> 00:17:36.530 into one continuous tube. 00:17:39.774 --> 00:17:44.919 ALLEN, CHRISTINA Houses on the other hand, are typically built up in layers. 00:17:44.920 --> 00:17:47.250 A lot of times they can. 00:17:47.250 --> 00:17:51.710 They're reinforced with textile metal or some type of other materials? 00:17:51.710 --> 00:17:56.540 ALLEN, CHRISTINA Sometimes you see a mixture of plastic with rubber, 00:17:56.540 --> 00:18:02.120 Umm in the layers, but that's the basic distinction between a tube 00:18:02.120 --> 00:18:06.450 and a hose is that tubes are typically a single extrusion 00:18:06.450 --> 00:18:09.810 while hoses are built up in layers. 00:18:12.900 --> 00:18:14.970 ALLEN, CHRISTINA So this is just. 00:18:18.024 --> 00:18:20.969 ALLEN, CHRISTINA An example of a cross section of a hose 00:18:20.970 --> 00:18:25.920 that has textile reinforcement, and you can see that it appears to be 2 layers 00:18:25.920 --> 00:18:31.520 of the plastic and then the center has what clearly looks like some type 00:18:31.520 --> 00:18:33.770 of textile in the middle. 00:18:36.525 --> 00:18:40.850 ALLEN, CHRISTINA Umm we also allow metal reinforcement and this type 00:18:40.850 --> 00:18:45.570 of metal reinforcement can come in the form of spiral wire. 00:18:45.570 --> 00:18:48.380 ALLEN, CHRISTINA A metal braid interior reinforcement 00:18:48.380 --> 00:18:52.310 or even a braided metal exterior reinforcement. 00:18:52.310 --> 00:18:58.230 And here you see a plastic ribbed hose that has been reinforced with metal. 00:19:04.025 --> 00:19:04.900 ALLEN, CHRISTINA Biddings. 00:19:04.900 --> 00:19:09.210 ALLEN, CHRISTINA Like I said earlier if the fittings are imported alone. 00:19:11.650 --> 00:19:15.880 ALLEN, CHRISTINA To be classified in 3917, they must be plastic, 00:19:15.880 --> 00:19:18.360 so do not get that confused with. 00:19:19.679 --> 00:19:38.409 ALLEN, CHRISTINA Umm so basically it bidding is exactly what you think it 00:19:38.410 --> 00:19:41.510 just connects tubes pipes and hoses. 00:19:41.526 --> 00:19:45.596 A lot of times you think of this, especially in pipes 00:19:45.596 --> 00:19:48.900 as the things like joints elbows flanges. 00:20:25.570 --> 00:20:30.160 ALLEN, CHRISTINA A twist type garden hose flow control nozzle 00:20:30.160 --> 00:20:35.820 or hose attachment with built in shut off valves would be in a 8481. 00:20:35.820 --> 00:20:38.950 ALLEN, CHRISTINA If it's just a hose connector. 00:20:38.950 --> 00:20:42.950 ALLEN, CHRISTINA That doesn't have any type of built-in valve. 00:20:42.950 --> 00:20:48.300 Then it would remain as just a hose fitting in 3917 dot 40. 00:20:48.300 --> 00:20:51.831 ALLEN, CHRISTINA Umm if it's a mechanical sprayer 00:20:51.832 --> 00:20:55.510 those can be classified in 8424. 00:20:57.525 --> 00:21:01.290 ALLEN, CHRISTINA Another big question that I get is about sprinkler heads. 00:21:02.650 --> 00:21:05.170 ALLEN, CHRISTINA While a sprinkler head is connected to. 00:21:07.525 --> 00:21:08.060 ALLEN, CHRISTINA A hose. 00:21:09.500 --> 00:21:12.700 ALLEN, CHRISTINA Sprinkler heads even if they're plastic 00:21:12.718 --> 00:21:14.020 are not hose fittings. 00:21:14.020 --> 00:21:16.590 ALLEN, CHRISTINA If the if the sprinkler head 00:21:16.590 --> 00:21:22.280 of plastic is non mechanical then it would be in 392490. 00:21:22.280 --> 00:21:26.850 ALLEN, CHRISTINA If it has mechanical function. 00:21:26.850 --> 00:21:31.530 ALLEN, CHRISTINA Umm in it, then it would be an 8424. 00:21:35.150 --> 00:21:35.800 ALLEN, CHRISTINA So. 00:21:36.774 --> 00:21:42.749 ALLEN, CHRISTINA Heading 3917 dot 31 covers high pressure hoses. 00:21:42.750 --> 00:21:47.600 ALLEN, CHRISTINA Umm I've had a lot of questions about it and and people 00:21:47.600 --> 00:21:51.310 when they read it because it is it seems very specific. 00:21:51.310 --> 00:21:56.520 ALLEN, CHRISTINA Umm flexible hoses tubes flexible tubes pipes 00:21:56.520 --> 00:21:59.670 and hoses that have a minimum burst pressure of 27.6. 00:21:59.670 --> 00:22:01.900 ALLEN, CHRISTINA Megapascals. 00:22:03.525 --> 00:22:06.450 ALLEN, CHRISTINA Umm a lot of people get hung up on that 00:22:06.450 --> 00:22:11.750 because that's not a term that we use a a lot here in the United States, 00:22:11.750 --> 00:22:13.250 so to make that simpler. 00:22:13.250 --> 00:22:18.850 ALLEN, CHRISTINA 27.6 Megapascals equals approximately 4000 pounds 00:22:18.850 --> 00:22:22.940 per square inch, which you would probably recognize as 4000 PSI. 00:22:22.940 --> 00:22:27.660 ALLEN, CHRISTINA Umm these extremely high pressure hoses. 00:22:30.399 --> 00:22:35.539 ALLEN, CHRISTINA Some types of pressure pressure washer hoses fit this 00:22:35.540 --> 00:22:40.640 because they but some of them, actually only are up to 3200. 00:22:40.640 --> 00:22:42.090 PSI so you would have to be. 00:22:42.090 --> 00:22:47.280 ALLEN, CHRISTINA Aware of the cut off that they to be classified here they 00:22:47.280 --> 00:22:50.530 still have to be 27.6 megapascals. 00:22:50.530 --> 00:22:53.570 ALLEN, CHRISTINA Which is 4 4000 PSI? 00:22:53.570 --> 00:22:58.850 ALLEN, CHRISTINA You will find that this type of host typically is used 00:22:58.850 --> 00:23:00.700 in more industrial settings. 00:23:02.468 --> 00:23:05.429 ALLEN, CHRISTINA That if you could have a pressure washer hose 00:23:05.430 --> 00:23:07.680 that someone used at home with that. 00:23:07.680 --> 00:23:11.470 You just would need to make sure you verify your PSI convert it 00:23:11.470 --> 00:23:14.000 to megapascals to be sure. 00:23:18.524 --> 00:23:23.049 ALLEN, CHRISTINA And the final debate that I have gotten Umm with these. 00:23:23.050 --> 00:23:27.570 ALLEN, CHRISTINA In this tech chapter have been fittings versus pipes 00:23:27.570 --> 00:23:31.520 and tubes and I've gotten quite a few questions. 00:23:31.520 --> 00:23:33.880 ALLEN, CHRISTINA About it. 00:23:33.880 --> 00:23:36.980 ALLEN, CHRISTINA Umm because sometimes you have. 00:23:36.980 --> 00:23:40.040 ALLEN, CHRISTINA A length of pipe and then there's a debate 00:23:40.040 --> 00:23:43.900 as to how do I determine if it is a fitting or if it is a pipe 00:23:43.900 --> 00:23:50.410 or 2 we have a recent ruling headquarters H 266146, 00:23:50.410 --> 00:23:57.200 which actually addresses the issues of fittings versus pipes and tubes first 00:23:57.200 --> 00:23:58.860 of all it affirms. 00:23:58.860 --> 00:24:04.150 The precedent that was set in headquarters 951940, 00:24:04.150 --> 00:24:07.010 which stated information made available to us. 00:24:07.010 --> 00:24:11.200 ALLEN, CHRISTINA Indicates that there is uniformity in the plumbing trade 00:24:11.200 --> 00:24:14.720 that cut to length steel pipe sections. 00:24:14.720 --> 00:24:20.360 Whether thread or not up to 12 inches in length are regarded as fittings 00:24:20.360 --> 00:24:21.680 and not tubes or pipes. 00:24:22.679 --> 00:24:26.839 ALLEN, CHRISTINA So it affirms what we've stood by for the long time that 00:24:26.840 --> 00:24:31.570 if a cut to length pipe section is 12 inches or less. 00:24:32.730 --> 00:24:33.980 They're regarded as fittings. 00:24:35.726 --> 00:24:39.999 ALLEN, CHRISTINA The ruling went further and provided further analysis 00:24:40.000 --> 00:24:43.950 that some items that are longer than 12 inches in length can 00:24:43.950 --> 00:24:48.210 still be considered fittings if they are not straight tubes 00:24:48.210 --> 00:24:53.330 and if they serve as connections from one apparatus to another 00:24:53.330 --> 00:24:56.910 while altering the flow of gases or liquids. 00:24:56.910 --> 00:24:59.760 So this is something that has been debated back and forth 00:24:59.760 --> 00:25:03.050 and we've answered a lot of questions about it, but this ruling. 00:25:05.024 --> 00:25:07.619 ALLEN, CHRISTINA In that the the attorney went further 00:25:07.620 --> 00:25:11.670 and did a further analysis on this and so basically. 00:25:11.670 --> 00:25:15.170 ALLEN, CHRISTINA Straight cut to length steel pipe sections threaded 00:25:15.170 --> 00:25:20.840 or not as long as they are 12 inches or less will be considered as fittings. 00:25:20.840 --> 00:25:22.710 ALLEN, CHRISTINA But. 00:25:22.710 --> 00:25:28.070 ALLEN, CHRISTINA An item longer than 12 inches as long as it is shaped 00:25:28.070 --> 00:25:33.330 and not straight in length, not a straight tube and it is used to connect. 00:25:33.330 --> 00:25:36.770 ALLEN, CHRISTINA Umm then that could be a fitting. 00:25:41.400 --> 00:25:44.440 ALLEN, CHRISTINA So we're now at everyone's favorite part 00:25:44.440 --> 00:25:45.800 so we're gonna look. 00:25:45.800 --> 00:25:47.860 I'm gonna look at the chat. 00:25:47.891 --> 00:25:52.961 ALLEN, CHRISTINA And see if we have any questions. 00:25:57.275 --> 00:25:59.160 ALLEN, CHRISTINA Give me a moment. 00:26:02.775 --> 00:26:04.800 ALLEN, CHRISTINA OK and like I said feel free to. 00:26:07.275 --> 00:26:09.990 ALLEN, CHRISTINA Type your questions in the chat box. 00:26:30.531 --> 00:26:32.290 ALLEN, CHRISTINA OK, so the first question I see is 00:26:32.290 --> 00:26:35.140 could you please define further worked. 00:26:37.150 --> 00:26:40.890 ALLEN, CHRISTINA Umm and I can't can basically. 00:26:43.025 --> 00:26:44.659 ALLEN, CHRISTINA Get to my notes. 00:26:56.789 --> 00:26:59.240 ALLEN, CHRISTINA OK, so basically it says if they're more than 00:26:59.240 --> 00:27:00.010 if they're not. 00:27:00.010 --> 00:27:04.580 ALLEN, CHRISTINA It's things like ground edges drilled. 00:27:04.580 --> 00:27:09.670 ALLEN, CHRISTINA Mild hemmed twisted framed or otherwise worked cut 00:27:09.670 --> 00:27:10.580 into shapes. 00:27:10.580 --> 00:27:14.700 I'm so if you have a straight profile shape that has just been extruded 00:27:14.700 --> 00:27:20.640 and it is exactly uniform as long as that action took place basically 00:27:20.640 --> 00:27:21.340 in that single. 00:27:21.340 --> 00:27:26.680 ALLEN, CHRISTINA Step that's considered not further work. 00:27:26.680 --> 00:27:32.590 ALLEN, CHRISTINA If it has holes or it has like a fitting attached to it. 00:27:34.219 --> 00:27:37.110 ALLEN, CHRISTINA Sometimes you see grommets or things like that. 00:27:38.400 --> 00:27:40.240 ALLEN, CHRISTINA That becomes further worked 00:27:40.240 --> 00:27:43.150 and therefore it would then have to be classified 00:27:43.150 --> 00:27:46.940 in another heading depending on exactly what it is. 00:27:53.525 --> 00:27:55.890 ALLEN, CHRISTINA What about metal drinking straws Umm 00:27:55.890 --> 00:28:00.490 those will not be covered in chapter 39 they would go 00:28:00.506 --> 00:28:04.769 into another chapter probably one of the metal chapters. 00:28:04.770 --> 00:28:08.470 I only cover drinking straws of plastic. 00:28:11.150 --> 00:28:12.450 ALLEN, CHRISTINA OK let's see. 00:28:15.900 --> 00:28:19.200 ALLEN, CHRISTINA Yeah, someone wants me to show slide 18 again. 00:28:19.200 --> 00:28:20.940 Give me a moment. 00:28:25.875 --> 00:28:28.656 ALLEN, CHRISTINA OK, I'll pop that up for just a second. 00:28:30.025 --> 00:28:31.124 ALLEN, CHRISTINA Umm. 00:28:38.525 --> 00:28:40.000 ALLEN, CHRISTINA And then 00:28:47.400 --> 00:28:52.156 ALLEN, CHRISTINA someone wants to see slide 32. 00:29:08.775 --> 00:29:11.449 ALLEN, CHRISTINA OK, I have this question, Umm When would 00:29:11.450 --> 00:29:16.030 if ever a plastic tube slash fitting be considered a part 00:29:16.030 --> 00:29:21.890 of a medical device classified in Chapter 90 DEG to deliver oxygen? 00:29:21.890 --> 00:29:25.270 ALLEN, CHRISTINA That is not a question that is 00:29:25.270 --> 00:29:29.840 within my purview basically when it becomes a part 00:29:29.840 --> 00:29:33.890 of something becomes a part of a medical advice device there are criteria. 00:29:33.890 --> 00:29:37.410 ALLEN, CHRISTINA That they look at to determine 00:29:37.410 --> 00:29:44.760 if the part is specialized to the device rather than being considered a part 00:29:44.760 --> 00:29:47.900 of general use such as a fitting so on that. 00:29:47.900 --> 00:29:52.450 ALLEN, CHRISTINA Umm that would that determination would actually be made 00:29:52.450 --> 00:29:55.920 by another NIS, Umm who handles chapter 90. 00:29:55.920 --> 00:30:00.640 ALLEN, CHRISTINA In discussions with me when they had the actual. 00:30:02.525 --> 00:30:04.020 ALLEN, CHRISTINA Fitting or tube. 00:30:13.150 --> 00:30:15.430 ALLEN, CHRISTINA OK, on the sprinkler heads and referring 00:30:15.430 --> 00:30:19.070 to mechanical versus non mechanical the lawn sprinkler 00:30:19.070 --> 00:30:21.312 that moved back and forth is considered? 00:30:22.150 --> 00:30:23.020 ALLEN, CHRISTINA Mechanical. 00:30:27.047 --> 00:30:28.850 ALLEN, CHRISTINA There's some other factors that go 00:30:28.850 --> 00:30:30.500 into mechanical versus mechanical. 00:30:30.500 --> 00:30:33.530 But yes if it has a mechanism. 00:30:33.530 --> 00:30:37.390 ALLEN, CHRISTINA That causes this action, yes in my 00:30:37.390 --> 00:30:42.070 that would be the case for mechanical would be if it's moving 00:30:42.070 --> 00:30:47.210 if it's just an opening that is allowing the sprinkler the water 00:30:47.210 --> 00:30:50.590 to come out of the sprinkler head, then that would be non mechanical. 00:30:55.149 --> 00:30:58.889 ALLEN, CHRISTINA Is elastomeric PVC considered plastic? 00:30:58.890 --> 00:31:00.760 ALLEN, CHRISTINA Or rubber. 00:31:00.760 --> 00:31:03.810 ALLEN, CHRISTINA Umm that is a little more complicated 00:31:03.810 --> 00:31:11.350 than just the average answer because we look at the actual chemical composition. 00:31:11.350 --> 00:31:17.650 ALLEN, CHRISTINA And the process to polymerize that product for us 00:31:17.650 --> 00:31:22.020 to make a determination as to whether something is plastic or rubber. 00:31:22.020 --> 00:31:25.990 There's there's a lot more complicated factors in than just a? 00:31:25.990 --> 00:31:28.780 ALLEN, CHRISTINA Across the board answer to that 00:31:28.780 --> 00:31:32.045 because there are last Americans used back and forth 00:31:32.053 --> 00:31:33.777 between plastic and rubber. 00:31:42.650 --> 00:31:46.110 ALLEN, CHRISTINA Question here could you clarify plastic fitting 00:31:46.110 --> 00:31:48.984 such as flanges that connect to implements 00:31:48.985 --> 00:31:51.190 which are other than tubes pipes 00:31:51.190 --> 00:31:57.410 and hoses for example, a plastic flange connecting a valve to the mineral tank 00:31:57.410 --> 00:31:59.440 still 3917 fittings. 00:31:59.440 --> 00:32:04.780 ALLEN, CHRISTINA That is more complicated as well, we look would have 00:32:04.780 --> 00:32:08.025 to look at actually how the Flange. 00:32:10.900 --> 00:32:17.010 ALLEN, CHRISTINA Is operating and then that would actually be reviewed by? 00:32:17.010 --> 00:32:22.770 ALLEN, CHRISTINA The NIS that handles valves, Umm to see 00:32:22.770 --> 00:32:28.090 if that Flange then is more complicated than just a simple connected fitting. 00:32:28.090 --> 00:32:31.340 ALLEN, CHRISTINA So I can't really answer that. 00:32:31.340 --> 00:32:34.920 ALLEN, CHRISTINA Without full information about it. 00:32:34.920 --> 00:32:39.430 ALLEN, CHRISTINA Where would steel or cast iron fittings be classified. 00:32:39.430 --> 00:32:44.470 I am going to have to defer that I am not positive. 00:32:44.470 --> 00:32:50.260 I would assume they would be considered some type of article of steel 00:32:50.260 --> 00:32:51.180 or cast iron. 00:32:51.180 --> 00:32:54.200 But I only handle plastics. 00:32:54.200 --> 00:33:00.760 So I don't know where those would be if you have a water hose that is 00:33:00.760 --> 00:33:05.610 being imported and it has a steel or cast iron. 00:33:05.610 --> 00:33:08.660 Probably not cast iron, but a steel fitting or aluminum fitting on the end. 00:33:08.660 --> 00:33:12.600 ALLEN, CHRISTINA It is being classified with the hose at that point 00:33:12.600 --> 00:33:18.000 because the fitting is already attached to the hose separately importing steel 00:33:18.000 --> 00:33:19.520 or cast iron fittings. 00:33:19.520 --> 00:33:20.100 I cannot answer. 00:33:23.650 --> 00:33:26.470 ALLEN, CHRISTINA What is the classification of hoses? 00:33:27.775 --> 00:33:30.240 ALLEN, CHRISTINA With metal reinforcements. 00:33:37.275 --> 00:33:40.789 ALLEN, CHRISTINA Umm basically if you just look straight to your tariff. 00:33:41.727 --> 00:33:46.437 ALLEN, CHRISTINA Hitting 3917 is all of the plastic. 00:33:46.459 --> 00:33:48.939 ALLEN, CHRISTINA Houses and if you look. 00:33:48.940 --> 00:33:55.540 ALLEN, CHRISTINA They have specifically over 3917. 00:33:55.540 --> 00:34:06.250 ALLEN, CHRISTINA Let me thought it lost my place. 00:34:11.525 --> 00:34:13.270 ALLEN, CHRISTINA You have the Headings where they break, 00:34:13.270 --> 00:34:17.880 it into it's not reinforced or combined with other materials. 00:34:17.880 --> 00:34:20.850 ALLEN, CHRISTINA Umm without fittings and not reinforced with fittings 00:34:20.850 --> 00:34:28.730 and then others 391739 and underneath that it has 0010 00:34:28.730 --> 00:34:33.530 which is reinforced with metal and then the section that is reinforced 00:34:33.530 --> 00:34:35.060 with other materials. 00:34:43.275 --> 00:34:43.680 ALLEN, CHRISTINA Umm. 00:34:45.775 --> 00:34:47.200 ALLEN, CHRISTINA Where would a plastic tube 00:34:47.200 --> 00:34:53.120 with a single fitting be classified it would be classified as a tube 00:34:53.120 --> 00:34:56.230 with fittings whether it's one bidding or 2 fitting. 00:34:56.230 --> 00:35:07.540 ALLEN, CHRISTINA And Jason Christie thankfully, UM is an NIS with me 00:35:07.540 --> 00:35:11.540 and my group and he had posted in the chat that many times 00:35:11.540 --> 00:35:15.960 with sprinklers a spring will make it mechanical so thank you Jason. 00:35:25.025 --> 00:35:27.720 ALLEN, CHRISTINA And so if they are not. 00:35:30.525 --> 00:35:33.220 ALLEN, CHRISTINA I'll do a Last Call for questions. 00:35:36.150 --> 00:35:38.970 ALLEN, CHRISTINA If there are any more give you a few more seconds 00:35:38.970 --> 00:35:43.280 to type those into the chat box. 00:35:46.525 --> 00:35:47.757 ALLEN, CHRISTINA In the meantime, 00:35:47.758 --> 00:35:50.090 I've just throw this back up as a reminder 00:35:50.090 --> 00:35:54.410 if you have something and would like a binding ruling. 00:35:54.410 --> 00:35:56.180 This is the link. 00:35:56.180 --> 00:35:59.250 ALLEN, CHRISTINA To our E ruling module. 00:36:02.525 --> 00:36:07.160 ALLEN, CHRISTINA And as always, we are available to assist you any time 00:36:07.160 --> 00:36:12.370 and so I'm going to post the contact information for myself and Lauren Zang 00:36:12.370 --> 00:36:15.720 in my office, who is the national import specialist associate. 00:36:16.930 --> 00:36:21.900 Feel free to reach out if you have questions and need any assistance 00:36:21.900 --> 00:36:23.500 and we are here to help you.