CLA-2-84:OT:RR:NC:N1:105
Sam Aspinall
Global Trade Consulting
L1/35 Ventnor Ave, West Perth WA 6005
West Perth 6038
Australia
RE: The tariff classification of the Produced Water Separator - Hydrocyclone Module (321 Module) from
the United Arab Emirates
Dear Mr. Aspinall:
In your letter dated May 14, 2025, on behalf of your client, Santos Limited – Oil Search (Alaska), you
requested a tariff classification ruling. Descriptive literature was provided for our review.
The item under consideration is described as the Produced Water Separator - Hydrocyclone Module (321
Module), which is industrial equipment used in the Nanushuk Processing Facility (NPF) to remove
particulates and oil from produced water through centrifugal and gravitational separation. Additional inputs
such as pumps and pump motors assist in this function by pumping the clean produced water into the next
module once it has been processed.
The module completes the separation function through the use of two hydrocylcones and a produced water
separator, which use centrifugal and gravitational forces to complete the separation. During operation, the
produced water flows into the module through pipes from the Inlet Separator and Low-Pressure Separator.
The equipment for the module is within the building structure to ensure protection from the elements. The
building serves as the central structure for the produced water to be filtered by the produced water separator
and two hydrocyclone centrifuges prior to its disposal. The two hydrocyclones have been specifically
designed and constructed to remove either sand or oil from the produced water, however, they complete the
same overall function of removing contaminants from the produced water.
The process within the module begins with produced water flowing into the produced water separator. The
produced water separator is a vessel that contains no mechanical components. The vessel utilizes weirs,
which are physical structures to facilitate the water and oil separation. The produced water enters the vessel,
where the oil, water, and gas will separate based on density and retention time in the vessel. Oil is removed
by spilling over a weir inside the vessel and the gas separates by rising up and out of the top of the vessel.
The heavier particulates settle at the bottom of the separator with the produced water and are piped to the
desanding hydrocyclone.
The desanding hydrocyclone is then used to separate particulates from the water. The slurry of heavy
particulates enters the desanding hydrocyclone on an angle and the desanding hydrocyclone uses centrifugal
force by swirling the water inside the vessel to complete the separation of particulates from the water. Once
the particulates have been separated, the produced water is then piped to the deoiling hydrocyclone.
The deoiling hydrocyclone is used to separate any entrained oil droplets from the water. The water flows into
the vessel, where centrifugal force swirls the water around inside of the vessel to complete the separation of
oil droplets from the water. After this process, the remaining water is clean and then pumped out of the
module to a produced water surge tank, which is a tank separate from the 321 Module and will be imported
separately.
Along with the major components, the module also has other minor components which work together to
make up the operational unit of the complete module. These components have been designed to be combined
as one complete unit to assist in completing the module’s primary function. The components include pumps,
pump motors, heaters, fans, and fan motors. The produced water booster pumps and motors are used to pump
clean produced water through to the produced water surge tank to the next module. Due to the surrounding
environment the module is designed to be operational in, the module includes building heaters, fans, and fan
motors which make up the module’s HVAC system. This HVAC system provides heating for the internal
space of the module to ensure the equipment remains operable and has no impact on the fluid processing.
In your letter, you suggest the applicable subheading for the Produced Water Separator - Hydrocyclone
Module (321 Module) to be under 8421.21.0000, Harmonized Tariff Schedule of the United States (HTSUS),
which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus,
for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or
purifying water.” We disagree. While the 321 Module does filter sand and oil from water, it primarily uses a
centrifugal motion to perform the operation, which is a function provided for earlier in heading 8421,
HTSUS.
By operation of Note 4 to Section XVI, HTSUS, the Produced Water Separator - Hydrocyclone Module (321
Module), imported in one shipment with all its interconnected components, constitutes a functional unit in
that its various components contribute together to a clearly defined function, which is centrifugal separation
of solids and sediments from process fluids.
Pursuant to General Rules of Interpretation (GRI) 1, Section XVI Note 4, and GRI 6, the applicable
subheading for the Produced Water Separator - Hydrocyclone Module (321 Module) will be 8421.19.0000,
HTSUS, which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and
apparatus, for liquids or gases; parts thereof: Centrifuges, including centrifugal dryers: Other.” The general
rate of duty will be 1.3 percent ad valorem.
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
8421.19.0000, 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division