CLA-2-84:OT:RR:NC:N1:103
Ashley Ahrens
Noatum Logistics
20 N. Martingale Rd., Ste. 200
Schaumburg, IL 60173
RE: The tariff classification of a polymerization reactor from Spain
Dear Ms. Ahrens:
In your letter dated March 16, 2026, you requested a tariff classification ruling on behalf of your client,
Schwartz Hautmont Construcciones Metalicas SA.
The subject polymerization reactor, item number 1R231, is described as a continuously stirred reactor
designed for polymerizing ethylene. It is made of high-strength carbon steel and has a 33,099-gallon
capacity. The reactor features a jacketed design and three sets of internal cooling coils, which are used to
control the heat generated by the exothermic reaction. It is also equipped with thermal elements, which work
together with steam circulating in the reactor jacket to provide heat to initiate the reaction process. Lastly, the
reactor has an agitator assembly that mixes the reactants and catalysts.
Headquarters (HQ) Ruling Letter 961365, dated June 24, 1998, reviewed a reactor vessel with a similar
configuration that was used to produce rubber latex emulsion. Based on the documents in your submission,
we find that the subject polymerization reactor is similar in both configuration and function to the reactor
reviewed in HQ 961365.
The applicable subheading for the polymerization reactor, item number 1R231, will be 8419.89.9580,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machinery, plant or
laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of
heading 8514), for the treatment of materials by a process involving a change of temperature such as heating,
cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing,
condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or
storage water heaters, nonelectric; parts thereof: Other machinery, plant or equipment: Other: Other: Other:
Other: For rubber and plastics.” The general rate of duty will be 4.2 percent ad valorem.
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 Huang at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division