Oil Rig Well Head Components not 'Taps, Cocks, or Valves' nor 'Parts of Boring Machinery,' CBP Says

Parts of an oil rig well head are properly classified as "other articles of iron or steel" rather than as parts for boring machinery or parts of taps, cocks and valves, CBP said in a recently released ruling the agency had issued in January.

Goods must be classified in their condition as imported, and the items, as imported, do not perform the function of opening or closing an aperture and are not parts of valves classifiable under Harmonized Tariff Schedule heading 8481, CBP said. And despite their stated use in boring or sinking, the articles are not integral to the function of boring or sinking apparatuses and are not classifiable as parts of boring or sinking machinery of heading 8431. Instead, the items generally serve secondary functions as conduits or adapters between components that do perform these functions, CBP said in HQ H293671

The parts at issue are distinct parts of wellhead and “Christmas Tree” assemblies for oil rigs. They consist of a tubing head adapter body, tee body and cross body, a casing head/casing spool, a housing and a packoff body.

As imported, the tee body and cross body are steel items designed as conduits for the flow of production fluid from the vertical main body to the horizontal valves of the Christmas Tree. The appliances in heading 8481 regulate the flow by opening or closing an aperture, according to the chapter's explanatory notes. The tee body and cross body do not perform the function of opening or closing an aperture, nor do they have any moving parts, CBP said.

The casing head is a steel article used as an adapter fitted between the first casing string and either the blow out preventer stack during drilling or the wellhead after drilling. The housing is a steel article that is to be connected to the blow out preventer via an adapter during drilling operations. After drilling, a tubing head, a double studded adapter, or the Christmas Tree will be attached to the adapter. The packoff body is a steel article that meant to seal off annular pressure between the inside diameter of the wellhead and the suspended casing or tubing. Neither the casing head, the housing nor the packoff body is integral to the function of opening or closing an aperture and so none of those is a part of a valve, the agency said.