The tariff classification of a shell and tube heat exchanger from Canada

N351458 August 8, 2025 CLA-2-84:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8419.50.5000; 9903.01.26 Natasha Salter Global Trade Consulting Pty Ltd L1/35 Ventnor Ave, West Perth Perth 6005 Australia RE: The tariff classification of a shell and tube heat exchanger from Canada Dear Ms. Salter: In your letter dated July 18, 2025, you requested a tariff classification ruling on behalf of your client, Santos Limited - Oil Search (Alaska). The merchandise under consideration is referred to as a Slop Rerun Heater and is described as a shell and tube heat exchanger. It is installed in the 331B Module, a building module that will be incorporated into the Nanushuk oil processing facility in Alaska. While the 331B building module will contain multiple subassemblies and other equipment, only the Slop Rerun Heater is under consideration in this request. The shell and tube heat exchanger is used to transfer heat between a glycol medium and a slop oil, which is a mixture of oil and water generated in the processing facility. Entering and leaving through separate inlets and outlets, the two fluids do not mix as they flow through the heat exchanger. The glycol medium flows through the shell side of the unit and the slop oil flows through the tubes. The applicable subheading for the Slop Rerun Heater will be 8419.50.5000, 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: Heat exchange units: Other.” The general rate of duty will be free. Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 8419.50.5000, HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 8419.50.5000, HTSUS. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Canada are not subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.26, in addition to subheading 8419.50.5000, HTSUS, listed above. The tariffs and additional 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/. 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 paul.huang@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division