CLA-2-84:OT:RR:NC:N1:102
Richard Rice
Samoa Corporation
90 Monticello Rd
Weaverville, NC 28787
RE: The tariff classification of a pump module from Spain
Dear Mr. Rice:
In your letter dated August 27, 2025, you requested a tariff classification ruling. Descriptive information was
provided with your submission.
The product at issue is the Evacumaster 3797 pump module. The module consists of a vacuum meter encased
with a piston pump, a pedestal, an inlet filter, an air regulator, a suction hose, connections and four different
probes. In use, the pump is mounted on a pedestal, and a probe is submerged into the engine oil of an
automobile, the pump then suctions oil that is transferred to an oil waste tank using a suction hose. The
module is used in locations where engine oil is changed.
The applicable subheading for the pump module will be 8413.19.0000, 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: Pumps fitted or designed to be fitted with a measuring device: Other. The
general rate of duty will be Free.
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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e., 9903.02.20, in addition to subheading 8413.19.0000, 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)
Denise Faingar
Acting Director
National Commodity Specialist Division