CLA-2-84:OT:RR:NC:N1:102
April J. Collier
Pacific Customs Brokers Inc.
1480 A Street
Blaine, Washington 98230
RE: The tariff classification of a Liquefaction Train from Italy.
Dear Ms. Collier:
In your letter dated July 10, 2015 you requested a tariff classification ruling.
The item under consideration is a Liquefaction Train. The conversion of natural gas to liquefied natural gas is said to involve gas treatment, gas compression and refrigeration. The Liquefaction Train provides the refrigeration, as it cools the natural gas and is described as the dual-closed loop, integration refrigeration system. This system consists of a gas turbine, a 20 megawatt motor, a four stage compressor for propane, a single stage compressor for mixed refrigerant and a single stage, medium to high pressure compressor for mixed refrigerant. The Liquefaction Train components are mounted on a single foundation and connected by a drive shaft that is powered by the gas turbine and the motor.
For transportation purposes, the components are imported unassembled. All the equipment needed to assemble the system is included.
Under the General Rules of Interpretation (GRIs) to the Harmonized Tariff Schedule of the United States (HTSUS), at GRI 2 (a), when components in unassembled or disassembled condition (incomplete or unfinished condition too) are exported on one shipment, even in separate boxes, and have the essential character of the completed good, the classification of the good is that of the completed article.
The Liquefaction Train is a refrigeration system that cools the natural gas by allowing the gas to condensate into liquefied natural gas. Refrigerating equipment is provided for in HTSUS heading 8418. Therefore, in accordance with GRI 2(a), the applicable subheading for the Liquefaction System will be 8418.69.0180, HTSUS, which provides for Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps, other than the air conditioning machines of heading 8415; parts thereof; Other refrigerating or freezing equipment; Other; Other refrigerating or freezing equipment. The rate of duty is 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 Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division