CLA-2-84:OT:RR:NC:N1:102
Gerald Francese
TradeLaw PC
PO Box 1114
110 Tom Harvey Rd
Westerly, RI 02891
RE: The tariff classification and country of origin of fracking units
Dear Mr. Francese:
In your letter dated January 19, 2026, you requested a tariff classification on behalf of your client, Jereh
Energy Equipment and Technologies Corporation. You also request a country of origin determination for the
purpose of marking, and Section 301 trade remedies, and other duties.
The products at issue are referred to as Trailer Mounted Intelligent Electrical Fracking (TMEF) Units, model
numbers YLT105-5600E, YLT95-5600E, and YLT105-6000E. Each unit is a trailer equipped with an
electrically powered Quintuplex Plunger Pump assembly, a power assembly, high- and low-pressure
assemblies, a lubrication system, a power-end lubrication assembly, a medium-voltage drive assembly, a
variable-frequency drive assembly, an electrical cabinet and a control assembly. Once powered by an electric
grid or a Power2Go gas turbine generator set, these assemblies work together to pump various types of fluids
used for oil and gas fracturing operations. The TMEF units are differentiated by their temperature thresholds,
working pressures and power output.
The plunger pump assembly consists of a Quintuplex plunger pump (power and fluid ends and a reducer), a
return oil pipe and a cover plate assembly. The pump, which is configured as a reciprocating positive
displacement pump pressurizes the low and medium pressure water supplies and then delivers the water
through a designated manifold.
The power assembly consists of an oil cooler pre-assembly, a drive shaft, a medium-voltage motor, and other
power assembly components. Its function is to transmit power from the motor to the plunger pump via a drive
shaft.
The high-pressure assembly consists of a pressure sensor, a hose bracket, a wing nut and a male plug.
The low-pressure assembly consists of lubrication pipe, a cast manifold, a hose bracket, an accumulator and a
u-type liquid inlet. Together, the components convey the low-pressure water supply to the plunger pump.
The packing lubrication assembly consists of a lubrication pump and hose connections. The function of the
assembly is to lubricate the five-way packing of the plunger pump.
The power-end lubrication assembly is driven by a motor that powers two double pumps, which provide
lubrication for the bearings and gears inside the power end of the plunger pump. The gear pumps suction lube
oil from the oil tank through suction oil filters and then deliver oil to the plunger pump via pipelines.
The medium voltage drive assembly is used for electrical frequency conversion and voltage transformation to
satisfy the needs of power supply scenarios.
The variable frequency drive assembly consists of five outdoor units that are used to control the actuation and
speed control of the lubrication motor.
The electrical cabinet houses all electrical controls for the TMEF unit, including sensors, sensor cables, main
motor power cables, lubrication motor power cables and other components.
The control assembly is a centralized point of access for all electrical equipment and protection of equipment
safety
The applicable subheading for the TMEF units will be 8413.50.0090, 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 reciprocating positive displacement pumps: Other: Other. The general
rate of duty will be Free.
With regard to origin, each TMEF unit is assembled in the United Arab Emirates. The final assembly process
involves installing the main assemblies either in their complete manner or as individual components onto a
trailer, all of which are sourced from China. The only exceptions to this Chinese sourcing are the drive shaft,
which comes from Germany, and the fluid end, which is sourced from the United Arab Emirates. Prior to
final assembly, the components of these main assemblies undergo sandblasting and painting.
During final assembly, components such as cable clips, clamps, cable trays, grounding posts, base plates,
latches, hinges, reinforced sleeves, fastening plates, brackets, fenders, and ladder brackets, all sourced from
China, are fitted and welded onto the trailer. Next, the main assemblies are mounted and secured onto the
trailer using bolts and screws, either as complete units or as individual components. As needed, anti-adhesion
agent is applied, cylindrical pins are positioned, and grease is applied. Once all assemblies and their
individual components are secured, clamp connections and connecting pipes, also sourced from China, are
attached to the various assemblies, and all electrical connections are completed. Each TMEF unit undergoes
testing. Finally, each TMEF unit is covered with a tarpaulin and secured using straps.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling
Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will
occur is whether an article emerges from a process with a new name, character, or use different from that
possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778
(C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v.
United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
The final assembly process in the United Arab Emirates involves mounting, bolting, and securing the
assemblies and their components onto a trailer, which are then connected using pipes, clamp connections, and
electrical wires. While these assemblies and their individual components are bulky and heavy, requiring
machinery for placement onto a trailer, the processes to complete each TMFE unit are not particularly
complex. The processes do not transform the Chinese assemblies, trailer, and other components, which
account for over 85 percent of value, so that they possess a new name, character, or use distinct from their
pre-installation state. The end-use of these articles, including the assemblies (integral to the process of
pumping fluid) and the trailer (which enables the assemblies to operate as a unit), is predetermined before
they arrive in the United Arab Emirates. Therefore, based on the totality of the circumstances, the origin of
the TMFE units will be China.
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.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division