CLA-2-84:OT:RR:NC:N1:102
Natasha Salter
Global Trade Consulting
L1/35 Ventnor Ave, West Perth WA 6005
West Perth 6038
Australia
RE: The tariff classification of compressor modules from the United Kingdom or Brazil
Dear Ms. Salter:
In your letter dated May 15, 2025, on behalf of Santos Limited – Oil Search (Alaska), you requested a tariff
classification ruling. Descriptive literature was provided for our review.
The 421 and 422 Flash Gas Compressor Modules are individual modules that sit parallel to each other when
installed at the Nanushuk Processing Facility in Alaska. Each module is comprised of a flash gas suction
scrubber, a flash gas suction scrubber pump, a flash gas compressor with an 1850 horsepower motor, a lube
oil separator, a lube oil pump, a lube oil exchanger, a lube oil filer, and a heating, ventilation and air
conditioning (HVAC) system. The components are enclosed in a building and connected using pipes that
incorporate valves and instrumentation controls, and contribute to a principal function, which is to compress
streams of flash gas.
In both modules, flash gas, which is vapor that forms when liquids are exposed to a change in pressure or
temperature, enters the scrubber. In the scrubber, gas is filtered, and liquid is removed. The separated gas
then enters the module’s screw compressor, and its pressure is increased to approximately 180 pounds per
square inch gauge. The polyglycol based oil that is separated from the gas stream is transferred to the lube oil
separator, where the oil is cooled, filtered, and pumped back to the injection ports of the compressor. During
the various processes, the HVAC system maintains the temperatures required to meet the operational needs
of the module’s equipment, including the compressor.
By operation of General Rule of Interpretation 1 and Note 4 to Section XVI, the applicable subheading for
the 421 and 422 Flash Gas Compressor Modules will be 8414.80.1675, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for Air or vacuum pumps, air or other gas compressors and fans;
ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological
safety cabinets, whether or not fitted with filters; parts thereof: Other: except parts: Air compressors: Other:
Stationary: Rotary: Exceeding 74.6 kW. The general rate of duty will be Free.
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
8414.80.1675, 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 Sandra Martinez at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division