The tariff classification of compressor modules from the United Kingdom or Brazil

N349082
May 27, 2025
CLA-2-84:OT:RR:NC:N1:102
CATEGORY: Classification
TARIFF NO.: 8414.80.1675; 9903.01.25
Natasha Salter Global Trade Consulting L1/35 Ventnor Ave, West Perth WA 6005 West Perth 6038 Australia RE: The tariff classification of compressor modules from the United Kingdom or Brazil Dear Ms. Salter: In your letter dated May 15, 2025, on behalf of Santos Limited – Oil Search (Alaska), you requested a tariff classification ruling. Descriptive literature was provided for our review. The 421 and 422 Flash Gas Compressor Modules are individual modules that sit parallel to each other when installed at the Nanushuk Processing Facility in Alaska. Each module is comprised of a flash gas suction scrubber, a flash gas suction scrubber pump, a flash gas compressor with an 1850 horsepower motor, a lube oil separator, a lube oil pump, a lube oil exchanger, a lube oil filer, and a heating, ventilation and air conditioning (HVAC) system. The components are enclosed in a building and connected using pipes that incorporate valves and instrumentation controls, and contribute to a principal function, which is to compress streams of flash gas. In both modules, flash gas, which is vapor that forms when liquids are exposed to a change in pressure or temperature, enters the scrubber. In the scrubber, gas is filtered, and liquid is removed. The separated gas then enters the module’s screw compressor, and its pressure is increased to approximately 180 pounds per square inch gauge. The polyglycol based oil that is separated from the gas stream is transferred to the lube oil separator, where the oil is cooled, filtered, and pumped back to the injection ports of the compressor. During the various processes, the HVAC system maintains the temperatures required to meet the operational needs of the module’s equipment, including the compressor. By operation of General Rule of Interpretation 1 and Note 4 to Section XVI, the applicable subheading for the 421 and 422 Flash Gas Compressor Modules will be 8414.80.1675, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Air or vacuum pumps, air or other gas compressors and fans;

ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Other: except parts: Air compressors: Other: Stationary: Rotary: Exceeding 74.6 kW. The general rate of duty will be Free. Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs. ?All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8414.80.1675, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling?s issuance. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified 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 the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border 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 periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division