CLA-2-84:OT:RR:NC:N1:102
Lydia Pardini
Polsinelli PC
1401 I Street NW, Suite 800
Washington, DC 20005
RE: The tariff classification of pump parts from various countries
Dear Ms. Pardini:
In your letter dated February 10, 2026, you requested a tariff classification ruling on behalf of your client,
Compass Pump d/b/a Kinetiflo. Detailed product information was submitted with your request.
The items under consideration are described as five pump parts which will primarily be used to produce
vertical turbine pumps after importation. You state that the pumps are intended for liquids and almost
exclusively used in water-related applications. Additionally, you assert that all parts are cast ductile iron and
meet the American Society for Testing and Materials (ASTM) A536 standard for durability and reliability. In
your request, you stated the country of origin may be China, India, Saudi Arabia, Taiwan, or Vietnam.
The “pump bowl” (Part # A112LC01) houses the impellers and diffuser vanes which convert fluid velocity
into pressure as water moves upward. The bowl also directs water as it passes through the housed
components and provides structural support. The “suction case” (Part # A312LC01) is designed to intake
fluid entering the pump and direct it into the suction impeller for optimal flow geometry. The “discharge
case” (Part # A512WL61) is assembled into the top of the pump bowl assembly to connect the pump to a
threaded pipe and optimize flow as it enters the pipe. Review of the submitted pictures and diagrams revealed
a structure within the discharge case consisting of four arms holding a central ring to accommodate and
secure a “bowl shaft” component.
The “discharge head” (Part # H106SB01) is described as the top section that connects the pump from the
source of water and redirects pumped water to the delivery system. The “pump packing box” (Part #
H2119S1A) is described as the part through which the rotating shaft enters the pressured portion of the pump
assembly. It helps to stop water leakage while allowing room for lubrication to protect the shaft from wear.
You propose classification for the five pump parts in subheading 8413.91.9096, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for “Pumps for liquids, whether or not fitted with a measuring
device; liquid elevators; parts thereof: Parts: Of pumps: Other: Other.” We agree.
The applicable subheading for the five pump parts (A112LC01, A312LC01, A512WL61, H106SB01,
H2119S1A) will be 8413.91.9096, HTSUS, which provides for “Pumps for liquids, whether or not fitted with
a measuring device; liquid elevators; parts thereof: Parts: Of pumps: Other: Other.” The general rate of duty
will be Free.
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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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 Paul Taylor at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division