CLA-2-84:OT:RR:NC:N1:105
Diane Sutera
Global Customs Services, LLC
21 Fadem Road, Unit 14
Springfield, NJ 07081
RE: The tariff classification of filters from Italy
Dear Ms. Sutera:
In your letter dated October 22, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The first item under consideration is described as a CSD filtering cartridge (model CSD40000A10A), which
is a filter designed to operate under medium pressure levels of up to 50 bar. The filters deliver optimal
performance when used in hydrostatic drives, earthmoving machines, compressors, and converters. The
filters are easily replaced through a quick, clean, and simple procedure. This characteristic is said to be
particularly important in demanding work environments where conditions are highly deteriorated. CSD
cartridges can handle flow rates of up to 140 l/min. Utilizing the threaded end, the compact filter can be
directly mounted onto the engine or transmission. The filter element itself is engineered to resist deformation,
distortion, and strain, preventing any release of trapped contaminants. This enhances filtration performance
and allows for efficient contaminant accumulation, even under challenging conditions such as high
differential pressure or water hammer effects caused by cold starts and variable discharge flow rates. These
features make CSD spin-on filters suitable for use with lubricating oils, fuels, emulsions, and most synthetic
fluids.
The second item under consideration is described as the CF filter element series (model CF06540568), which
are devices installed on tank return line filters located near internal combustion engines and power
transmission systems. They are designed for the filtration of hydraulic oils in numerous engine-driven
systems and transmissions that support mechanical and process operations. These elements can handle flow
rates of up to 175 l/min, with a maximum working pressure of 6 bar. The filter operates in an
inside-to-outside flow configuration and is suitable for use with both mineral and synthetic oils in combustion
engine applications such as agricultural equipment, container hook loaders, and lorry-mounted cranes.
The third item under consideration is described as the DFN air/oil separator (model DFN2752401U). The
device is designed to retain most of the aerosol oil present in the compressed air flow, generated by
entrainment during screw or vane lubrication. The compressed air, contaminated by microscopic oil droplets
and solid particles, passes through the first layer of reinforced borosilicate microfibers. Within this layer, the
aerosol droplets, smaller than one micron in size, coalesce into larger drops. These are subsequently captured
and drained by a second layer of synthetic porous material, and, due to gravity, collect on the dry side of the
separator. The DFN separators are designed for a maximum flow rate of 10.3 m³/min and a maximum
working pressure of 20 bar. Air/oil separators are installed in a pressure vessel located inside the screw
compressor. During the compression process of oil-cooled compressors, oil is used to seal, lubricate, and cool
the air, which is later directed to large combustion engines. Thanks to the coalescence effect, the DFN
separators efficiently remove the residual oil contained in the compressed air within the pressure vessel. The
purified air is then available for distribution through the compressed air network. This process represents a
fundamental requirement for systems operating in industries such as food processing, electronics,
pharmaceuticals, and textiles, where clean, oil-free air is essential.
As suggested in your letter, the applicable subheading for the CSD filtering cartridges (model
CSD40000A10A) and CF filter element series (model CF06540568) will be 8421.23.0000, 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: Oil or fuel filters for internal combustion engines.” The general rate of
duty will be 2.5 percent ad valorem.
As further suggested in your letter, you assert the applicable subheading of the DFN air/oil separators (model
DFN2752401U) would be 8421.23.0000, HTSUS. We disagree. The purpose of the air/oil separator is not to
filter a liquid. Instead, it is pulling small liquid droplets from an air stream. Therefore, the air/oil separators
will be classified in the section of heading 8421 that applies to filtering gases. This would be consistent with
the oil separator that CBP classified in Headquarters Ruling H249755 (dated January 21, 2020).
Accordingly, the applicable subheading for the DFN air/oil separators (model DFN275240.1U) will be
8421.39.0190, 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 gases: Other: Other: Other: 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 subheadings 8421.23.0000 and 8421.39.0190, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division