CLA-2-84:OT:RR:NC:N1:102
Jeffrey Orenstein
K&L Gates LLP
1601 K St. NW
Washington, DC 20006
RE: The tariff classification of castings from Canada
Dear Mr. Orenstein:
In your letter dated September 10, 2025, you requested a tariff classification ruling on behalf of your client,
Ebara Elliott Energy. Descriptive information was provided with your submission.
The items at issue are impeller castings, part number 24E503AC02J1014A001, and shaft castings, part
number JS1100-135-3079542-1. The impeller castings are circular in shape and feature blade profiles, a
crossover bend curvature, return channel vane shapes, and a center bore into which a shaft can be inserted.
The shaft castings are designed to transfer rotational power to the impellers. The impeller and shaft castings,
which are constructed of steel material, are used in multistage centrifugal compressors that increase the
pressure of gas. The compressors are used in oil and gas production, petroleum refining, petrochemical
processing and other industrial processes.
In your letter, you suggest the shaft castings are classified within subheading 8414.90, 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: Parts. We disagree,
because while the shaft castings are used in compressors, power transmitting shafts used in compressors have
been classified within heading 8483. See New York Ruling R04125, dated June 27, 2006.
The applicable subheading for the impeller castings will be 8414.90.4190, 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: Parts: Of compressors: Other: Other: Other: Other. The general rate of duty will be Free.
The applicable subheading for the shaft castings will be 8483.10.5000, HTSUS, which provides for
Transmission shafts (including camshafts and crankshafts) and cranks; bearing housings, housed bearings and
plain shaft bearings; gears and gearing; ball or roller screws; gear boxes and other speed changers, including
torque converters; flywheels and pulleys, including pulley blocks; clutches and shaft couplings (including
universal joints); parts thereof: Transmission shafts (including camshafts and crankshafts) and cranks: Other
transmission shafts and cranks. The general rate of duty will be Free.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e., 9903.81.91, in addition to subheadings 8414.90.4190 and 8483.10.5000, HTSUS.
Derivative iron or steel products processed in another country from steel articles melted and poured in the
United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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. For
products covered by heading 9903.81.91 this additional duty applies to the non-steel content of the
merchandise. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.10, in
addition to subheadings 8414.90.4190 and 8483.10.5000, 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 subheadings 8414.90.4190 and 8483.10.5000, 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 of Canada are not
subject to reciprocal tariffs. 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 subheadings 8414.90.4190 and 8483.10.5000, 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division