The tariff classification of industrial wastewater pretreatment systems from Singapore

N336672 December 14, 2023 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 8421.21.0000 Hunter BlairDown to Earth Energy LLC201 Bold Springs AvenueMonroe, GA 30655 RE:  The tariff classification of industrial wastewater pretreatment systems from Singapore Dear Mr. Blair: In your letter dated November 21, 2023, you requested a tariff classification ruling. The first item under consideration consists of two ultrafiltration (UF) membrane vessels, which are a series of racks containing ultra filtration hollow-fiber membranes submerged in an open-topped rectangular vessel. The aerated vessel measures 30 feet long, 7 feet wide, and 8 feet high. The vessel itself is painted carbon steel, and the membranes are connected via plastic pipe that makes the headers. The hollow fibers are polyvinylidene fluoride (PVDF) membrane fibers connected via headers to a pump system that is controlled via a simple programmable logic controller (PLC) system. The two vessels will be set up to run in parallel with simple, staggered on/off timers. Water is sucked through the hollow fiber membranes in staggered time frames - usually 8 minutes on and 2 minutes off for each vessel. The UF water is sucked through the membranes then pumped into a holding tank to stage for the nanofiltration step. The entire UF membrane system is powered by electric pumps, electric blowers (for aeration), and a simple PLC cabinet that houses timers, starters, etc. This equipment is designed solely to filter water to the ultrafiltration level. Due to the polarity of the membranes themselves, this system is only suitable for filtering water and wastewater. The ultra-filtration membranes can be used by themselves without the additional step of nanofiltration depending on the cleanliness needs of the water. The vessels will be imported partially assembled in three shipping containers that will enter at the same time. The second item under consideration is described as the nano-filtration (NF) membrane skid, which is a series of six membrane tubes, three pumps, two guard filters, flow meters, pressure gauges, and all electronics and PLC controls mounted to a carbon steel skid. This skid is used in conjunction with the UF membrane vessels to further clean the wastewater stream. The water is pumped from a holding tank, first through a feed pump, then through two melt blown filter cartridge housings. Then the water is then shipped through a high-pressure pump where it is pressurized to a higher level (approximately 50 PSI) and pumped through the first stage of the NF membranes. Finally, the water flows through a booster pump before flowing through the second stage of NF membranes. The complete machine will be imported partially disassembled. As suggested in your letter, the applicable subheading for the ultrafiltration membrane vessels and the nano-filtration membrane skid will be 8421.21.0000, 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: For filtering or purifying water.” The general rate of duty will be free. 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/current. 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 jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division