CLA-2:OT:RR:NC:N1:104
Richard Rice
Samoa Corporation
90 Monticello Rd
Weaverville, NC 28787
RE: The tariff classification of a portable oil extractor and collection system from Spain
Dear Mr. Rice:
In your letter dated April 14, 2026, you requested a tariff classification ruling.
The product in question is the portable oil extractor and collection system, model 372700.300, described as a
mobile used-oil suction and collection system. The system is comprised of a 100-liter steel recovery tank, a
wheeled base with handle, and an external Evacumaster pneumatic suction pump module mounted on the
collector assembly together with an air-operated PM2 1:1 oil suction pump and its external hose/filter/probe
circuit. The unit is designed to extract used engine oil from vehicles via suction probes inserted into the
dipstick tube. The extracted oil is conveyed through the pump module and into the steel tank for temporary
accumulation prior to discharge.
In your request, you claim the portable oil extractor and collection system is similar to the pump module
discussed in New York Ruling N352993, dated September 11, 2025, and suggest its classification under
heading 8413, Harmonized Tariff Schedule of the United States (HTSUS), which provides for pumps for
liquids, whether or not fitted with a measuring device; liquid elevators. We disagree. The portable oil
extractor and collection system features a pump mounted to the exterior of a 100-liter collection tank that
accumulates and stores collected oil. Since this system performs functions, such as fluid accumulation and
storage, which exceed the scope of heading 8413, it is excluded from classification under this heading.
The applicable subheading for the portable oil extractor and collection system will be 8479.89.9599, HTSUS,
which provides for machines and mechanical appliances having individual functions, not specified or
included elsewhere in this chapter; parts thereof: other machines and mechanical appliances: other: other:
other. The general rate of duty will be 2.5 percent ad valorem.
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 Arthur Purcell at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division