CLA-2-84:N:N1:105 878127

Mr. Joseph P. Kane
North American Tire Recycling Ltd.
1800 Diagonal Road, #600
Alexandria, Va. 22314

RE: The tariff classification of " The Multi-Purpose Disposer Batch Pyrolysis System" from England.

Dear Mr. Kane:

In your letter dated August 17, 1992 you requested a tariff classification ruling. The "Multi-Purpose Disposer (MPD) Batch Pyrolysis System" is designed to recycle scrap tires, medical waste, used oil filters and other dry organic waste streams by pyroylsis. Pyrolysis is the process of breaking down organic chemical bonds by the action of heat. This pyrolysis process takes place in a closed oxygen- free kiln at very high temperatures in the range of 840 to 860 degrees C. (1544 to 1580 degrees F.). The intense heat causes the tires (or other dry organic waste feedstock) to break down into four component by-products: carbon-rich char, pyro-gas, pyro-oil and steel. The system is fueled by natural gas, pyro- gas, diesel fuel or pyro-oil. Components of the system include, among others: a kiln furnace, dual furnace burners, condensers, a gas scrubber, filters, pumps, and piping.

All of the components will be imported in the same shipment. The applicable subheading for the "MPD Batch Pyrolysis System", a functional unit, noting Section XVI, Note 4 of the Harmonized Commodity Description and Coding System, will be 8417.80.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other nonelectric industrial or laboratory furnaces and ovens. The rate of duty will be 5.7 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport