CLA-2-84:OT:RR:NC:N1:103
Natasha Salter
Global Trade Consulting
L1/35 Ventnor Ave
West Perth 6005
Australia
RE: The tariff classification of a crude cooler module from Canada
Dear Ms. Salter:
In your letter dated May 15, 2025, you requested a tariff classification ruling on behalf of your client, Santos
Limited – Oil Search (Alaska).
The merchandise under consideration is identified as the 241 Crude Cooler Exchanger Module which will be
incorporated into the Nanushuk Processing Facility, a modular plant currently under construction in Alaska.
When construction is complete, this facility will process oil deposits from the Nanushuk reservoir into sales
quality oil.
The function of the 241 Crude Cooler Exchanger Module is to cool crude oil before it enters a downstream
module. Its main components include a sales oil mixer, four crude coolers, piping, valves, instrumentation
and controls. Other components include exhaust fans, fan motors, building heaters, and heater motors. As the
Nanushuk Processing Facility is in Alaska, the building heaters and exhaust fans are included to heat the
module building and provide air circulation. They do not have an impact on fluid processing.
The four crude coolers will be configured as steel shell and tube heat exchangers, where treated crude oil
flows into the shell side of the unit and cold medium flows through the tube side of the heat exchanger. The
two fluids do not mix as they move through the unit, with the crude oil exiting at a lower temperature and the
cold medium exiting at a higher temperature. Connected downstream to the crude coolers is an oil sales
mixer that turns the crude oil into a homogenized mixture as it exits the module. The mixer is not mechanical
but described as a carbon steel plate with a specially shaped opening.
In your request, you suggest the 241 Crude Cooler Exchanger Module is classifiable under subheading
8419.50.5000, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The module is
imported in a single shipment with interconnected components and classified pursuant to Note 4 to Section
XVI. Note 4 covers machines consisting of separate components that are intended to contribute together to a
clearly defined function. Here, the components contribute together to perform a function covered by heading
8419, i.e., the treatment of materials by a process involving a change of temperature.
Regarding the subheading, General Rule of Interpretation (GRI) 6 requires that the classification of goods in
the subheadings of headings shall be determined according to the terms of those subheadings, any related
subheading notes, and to the GRIs. We note that the crude oil is only treated within the shell and tube heat
exchangers and exits the module without any other processing.
Pursuant to GRI 1 (Section XVI Note 4) and GRI 6, the applicable subheading for the 241 Crude Cooler
Exchanger Module will be 8419.50.5000, HTSUS, which provides for “Machinery, plant or laboratory
equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading
8514), for the treatment of materials by a process involving a change of temperature such as heating,
cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing,
condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or
storage water heaters, nonelectric; parts thereof: Heat exchange units: Other.” The general rate of duty will be
free.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At
the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to
subheading 8419.50.5000, HTSUS, listed above. Articles that are entered free of duty under the terms of
general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set
forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be
subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 8419.50.5000, HTSUS.
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. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.26, in addition to subheading 8419.50.5000, 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 Paul Huang at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division