CLA-2-84:OT:RR:NC:N1:102
Natasha Salter
Global Trade Consulting Pty Ltd
L1/35 Ventnor Avenue
West Perth, Australia 6005
RE: The tariff classification of a pump subassembly from Canada
Dear Ms. Salter:
In your letter dated July 18, 2025, on behalf of Santos Limited – Oil Search (Alaska), you requested a tariff
classification ruling. Descriptive information was provided with the submission.
The Pump Subassembly consists of a Divert Water Pump and a Slop Water Pump. The Divert Water Pump
and Slop Water Pumps receive separate streams of processed water from separate tanks in a tank farm
installed at the Nanushuk Processing Facility in Alaska. The two pumps are configured as centrifugal pumps
and once mounted onto a frame and connected to separate piping systems, the divert pump circulates water
from the divert and slop tanks within the 331B module onwards. The pumps are single stage, single suction
pumps that each feature a discharge outlet that measures 2.38 inches in diameter.
The applicable subheading for the individual pumps will be 8413.70.2022, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for Pumps for liquids, whether or not fitted with a measuring
device; liquid elevators; part thereof: Other centrifugal pumps: Other: Other: Single-stage, single-suction,
frame- mounted: With discharge outlet under 7.6 cm in diameter. 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 35 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 8413.70.2022, 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 8413.70.2022, 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 8413.70.2022, 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)
James Forkan
Acting Director
National Commodity Specialist Division