CLA-2-84:OT:RR:NC:N1:105
Natasha Salter
Global Trade Consulting Pty Ltd.
L1/35 Ventnor Avenue
West Perth, WA 6005
Australia
RE: The tariff classification of a flash gas separator module from Canada
Dear Ms. Salter:
In your letter dated May 29, 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 222 Low Pressure Flash Gas Separator Module, which is a
filter module installed in the Nanushuk Processing Facility (NPF) in Alaska. The module consists of a
low-pressure flash gas separator, low pressure flash gas separator pumps, piping, valves, instrumentation, and
controls to create a complete operational module. As the NPF is located in Alaska, the module also includes
building heaters, building heater motors, exhaust fans, and exhaust fan motors.
The 222 Low Pressure Separator Flash Gas Module is part of the flash gas separation assembly. The
assembly is comprised of three other components, a safety valve platform and two flash gas coolers. These
sections have been shipped separately from this module and are not included for the purposes of this ruling
request.
The function of the 222 Low Pressure Separator Flash Gas Module is to separate hydrocarbon liquids (crude
oil) from the incoming flash gas process stream. Flash gas is produced in the NPF as a consequence of the
crude oil production process. As the crude oil is exposed to lower pressures, this depressurization causes
some of the crude oil to spontaneously vaporize, thus creating flash gas. Prior to entering the 222 Low
Pressure Separator Flash Gas Module, the flash gas stream enters the low-pressure flash gas separator
coolers. In the coolers, the temperature of the flash gas is reduced to a point that condenses the hydrocarbons
back into liquid form while other gases and contaminants remain as vapor. This stream then travels from the
cooler into the 222 Module (the cooler ships separately to this module).
When operational, the stream enters the flash gas separator via the module’s interconnecting piping. The
flash gas separator is a vertical tank made from material SA-516-70N which is a normalized steel pressure
vessel. It is in this vessel that the hydrocarbon liquids separate from the gas stream partially through gravity
and density and partly through the mesh pads and vane packs. As the gas rises in the flash gas separator, the
gas is filtered through the mesh and vane assembly on the gas outlet. These mesh pads and vane packs
provide a surface area for liquid droplets to coalesce and separate from the gas stream. As the gases exit the
vessel they are routed via the piping to the flash gas suction scrubbers, or the low-pressure flare knock out
drum (both not included in the 222 Module). While this process occurs, the heavier hydrocarbon liquids settle
at the bottom of the vessel. The hydrocarbon liquids are then transferred to the flash gas separator pumps
where the recovered hydrocarbon liquids are transferred for further processing in the NPF.
By operation of General Rule of Interpretation 1 and Note 4 to Section XVI, the applicable subheading for
the 222 Low Pressure Flash Gas Separator Module will be 8421.29.0065, 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: Other: Other: Other: 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 8421.29.0065, 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 8421.29.0065, 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 8421.29.0065, 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division