CLA-2-84:OT:RR:NC:1:120

Dear Ms. Vivien Hammett
Gardner Denver, Incorporated
1800 Gardner Expressway
Quincy, IL 62305

RE: The tariff classification of desiccant dryers from China

In your letter dated September 28, 2011 you requested a tariff classification ruling.

The merchandise under consideration includes the Gardner Denver desiccant dryers (DGH and GDHM series). The principal function of the composite machine is to dry compressed air by removing moisture from the saturated desiccant tower, which is a dewatering process. The machine incorporates twin desiccant towers, a control system and strategically positioned valves that are specially designed for switching and purge (removal of moisture) operations.

Incoming air enters the dryer through a valve, where it is directed to the bottom of the tower containing the desiccant. The desiccant removes 99.7 percent of the water vapor from the air by simply passing through the desiccant bed. The dried air exits the dryer system through a valve located at the top of the desiccant tower, to continue through the compressed air system. The desiccant is regenerated by some of the dried air that is siphoned off before exiting the dryer.

One tower dries the air while the other tower is regenerated. There are two towers so that air can be dried continuously. If there was only one tower, the dryer would have to pause while the tower regenerated, and the system would not receive dried air during this time.

The standard control system for the DGH allows for dew point selection, programmable shut-downs to synchronize with air compressor, service alarms and reminders, status indicators for the valves and towers, and RS-232 communication ports. The control system on the GDHM does not have a power on/off switch. It only has a timer system that controls the valves and determines which tower the air passes through.

The applicable subheading for the desiccant dryers will be 8421.39.8015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for filtering or purifying machinery and apparatus for gases: other: other. The rate of duty will be free.

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 on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Denise Faingar at (646) 733-3010.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division