CLA-2-84:OT:RR:NC:N1:102
Natasha Albertini
Global Trade Consulting
L1/35 Ventnor Avenue
West Perth, WA 6005
Australia
RE: The tariff classification of a compressor module from Canada
Dear Ms. Albertini:
In your letter dated May 25, 2025, you requested a tariff classification ruling on behalf of Santos Limited –
Oil Search (Alaska).
The 461 Fuel Gas Import Compressor Module is installed at the Nanushuk Processing Facility in Alaska. The
module consists of a fuel gas heater, a fuel gas booster compressor suction scrubber, fuel gas booster
compressor suction and discharge bottles, a discharge coalescer, a discharge coalescer sump, a compressor
frame lube oil supply tank, a compressor cylinder lube oil supply tank, a 8 81 kilowatt gas compressor, a
waste oil tank, a seal pot vacuum pump, a seal pot, and a heating, ventilation and air conditioning (HVAC)
system. The components, which are enclosed in a building and connected using pipes that incorporate valves
and instrumentation controls, contribute to a principal function, which is to compress natural gas used to
generate electricity.
When the module is in operation, the gas, which varies in pressure, flows into the fuel gas heater, where the
gas is heated to an optimal pressurization temperature. Afterwards, the heated gas flows into the scrubber to
remove entrained liquids from the gas stream. The gas stream then flows into a suction bottle, which
functions as the inlet of the compressor cylinder, and continues to flow into the reciprocating compressor,
exiting a discharge bottle before entering the coalescer where minute amounts of lube oil are filtered from the
gas stream. The oil that is separated from the gas stream is returned to the compressor. The seal pot and
vacuum pump capture the small nitrogen vent stream from the compressor cylinder and transfer the stream to
a separately located flare. 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 461 Fuel Gas Import Compressor Module will be 8414.80.2075, 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: Other compressors:
Other: Other, including reciprocating and rotary: Exceeding 746 kW. 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 8414.80.2075, 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 8414.80.2075, 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 8414.80.2075, 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division