CLA-2-84:OT:RR:NC:N1:105
Natasha Salter
Global Trade Consulting
L1/35 Ventnor Ave., West Perth WA 6005
West Perth 6038
Australia
RE: The tariff classification of the Centrifuge Module (346 Module) from the United States
Dear Ms. Salter:
In your letter dated May 21, 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 Centrifuge Module (346 Module), which is a dual-level
fully-integrated packaged unit designed to remove solids and sludge from process streams within the
Nanushuk Processing Facility (NPF). It functions as a critical part of the overall waste treatment system and
is delivered as a prefabricated, self-contained structure. The module includes four centrifuges, two centrate
tanks, two centrate pumps, and all piping, valves, instrumentation, controls, and electrical systems required
for operation, as well as the necessary inlet and outlet connections to interface with the facility pipe-rack.
The module has been engineered as a single operational asset, with each component purpose-built to
contribute to the common goal of efficient solids separation. While the individual equipment items perform
different functions, they work together seamlessly to ensure a reliable, continuous process. Once operational,
the module is designed to receive sludge from other facilities in the NPF, which is aided by the sludge
transfer pumps. The sludge that is pumped into the 346 Module travels through the interconnecting piping
and is distributed among the four Elgin Brand ESS-936-HD2 centrifuge assemblies on the upper level.
The centrifuges operate by spinning the sludge at high speeds resulting in the solids (sludge) separating from
the liquids. The end product from this process is known as centrate (liquid), which is then transferred to the
centrate tanks before being pumped to the produced water separator in the NPF facility. The remaining solids
from the centrifugal process are transferred to the sludge removal bins on the lower level of the 346 Module
and will be removed via trucks once full.
In your letter, you suggest the applicable subheading for the Centrifuge Module (346 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 346 Module does perform a filtering function, 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 Centrifuge Module (346 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 from process fluids.
Pursuant to General Rules of Interpretation (GRI) 1, Section XVI Note 4, and GRI 6, the applicable
subheading for the Centrifuge Module (346 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.
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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division