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 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 231 Low Pressure Separator Module, which is a filter
module installed in the Nanushuk Processing Facility (NPF) in Alaska. The module consists of a
low-pressure separator, a low-pressure separator desand transfer pump, a low-pressure separator emulsion
pump, piping, valves, instrumentation, and controls to create a completely 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 purpose of the 231 Low Pressure Separator Module is oil separation, with input streams consisting of a
combination of crude oil with water and gas contaminants. In this module, the oil is separated from gas and
water with each of the streams then piped for further processing within the NPF. Separation occurs in the
low-pressure separator based on density and residence time for fluids in the vessel, the vessel internal also
contains steel baffle plates which aid in the separation process. The low-pressure separator is a 3-phase
separator with three streams exiting the vessel being gas, crude oil, and produced water. Separation is assisted
by the baffle plates internal to the vessel. As temperature and density of the fluids impact performance of this
vessel, the inlet fluids are heated using the upstream crude oil heaters included as a part of the 223 Vessel
once the full system is installed on-site.
The low-pressure separator desand transfer pump and low-pressure separator emulsion pump in the 231
Module are intermittent service pumps. Both of these pumps service the low-pressure separator and aid in the
overall function of the oil separation. When operational, emulsion, which is an oil and water mixture, can
build up and form a layer in the low-pressure separator vessel. The low-pressure separator emulsion pump
functions by pumping this emulsion from the low-pressure separator back to other areas in the NPF for
further processing. Additionally, as crude oil enters the low-pressure separator, residue sand may follow. This
sand builds up in the separator, collecting as a sand layer at the bottom of the vessel. Nozzles within the
separator stir up the sand and remove it from the separator as a sand and water slurry. This slurry is then
pumped from the low-pressure separator using the low-pressure separator desand transfer pump to other
facility areas in the NPF.
By operation of General Rule of Interpretation 1 and Note 4 to Section XVI, the applicable subheading for
the 231 Low Pressure Separator Module will be 8421.29.0015, 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: Oil-separation equipment.” 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 8421.29.0015, 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 8421.29.0015, 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