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CSMS #42133823 - Entry Summary Guidance for Pipe Spools from Multiple Countries of Origin

Pipe spools are prefabricated components of a piping system consisting of various types of pipes, flanges, elbows, and fittings, and may contain line pipes and other components manufactured in multiple countries. Pipe spools, made of steel, may be subject to Section 232 duties or quotas, Section 301 duties, as well as antidumping and countervailing duties (AD/CVD), based on the country of origin of the component and the AD/CVD scope.

It is not uncommon for a pipe spool to be manufactured with pipes and other components from multiple countries. While the entire pipe spool has one tariff classification, the country of origin of the components of the pipe spool is unique to each component (See NY N284041, dated March 31, 2017, NY N262359, dated April 6, 2015, and NY N245495, dated September 17, 2013 see also HQ H005109, dated April 12, 2007).

In order to properly report the applicable trade remedies and/or AD/CVD on each pipe spool component, filers are required to break out each component of the pipe spool by the country of origin. For example, if all the components have the same country of origin, the filer reports the pipe spool on one line. However, if either:
(a) the pipe spool has components from two or more countries of origin; and/or
(b) the pipe spool has components that are subject to requirements such as antidumping and or countervailing duties, Section 232 or 301 duties, or quotas;
the filer reports the pipe spool on multiple lines, as needed, to reflect the different country and requirements (including trade remedies and/or AD/CVD proceeding(s)). All other reporting requirements, such Section 232 or 301 exclusions (if applicable), should also be reported on the corresponding line.

Each line should use the same tariff classification as the classification for the entire pipe spool.

To determine the amount of duty or quota quantity on each line, apportion the value of each line based on the value of each component of the pipe spool. The quantity on each line should be apportioned based on the percentage of value; for example, if the total quantity of pipe spools is 80, and the component on a line has 10 percent of the total value of the pipe spool, then the quantity reported on that line is eight, which is 10 percent of the total quantity. (See attachment for example).

In compliance with CBP invoice requirements, the commercial invoice must include, among other things, a detailed description of the merchandise, materials, value, quantity, HTSUS, and country of origin (See 19 CFR 141 Subpart F for full requirements). The invoice and supporting documents must provide sufficient information to determine, among other things, the value, quantity, HTSUS, and country of origin of the components of the pipe spool.

For further guidance, contact your Center of Excellence and Expertise, or request a ruling from CBP’s Office of Regulations and Rulings at https://www.cbp.gov/trade/rulings.