CLA-2-84:OT:RR:NC:N1:120
Ms. April J. Collier, LCB, CCS
Pacific Customs Brokers Incorporated
P.O. Box 4505
Blaine, WA 98230
RE: The tariff classification of Heat Recovery Steam Generator (HRSG) parts from China
Dear Ms. Collier:
In your letter dated June 21, 2012, you requested a tariff classification ruling on behalf of your client, CMI EPTI LLC.
The merchandise under consideration consists of four items that include steam drums, an exhaust stack, module boxes, and inlet duct panel assemblies. These items are integral parts of a complete two duct-fired HRSG, which is a super-heated water boiler operating under constant pressure in a closed circuit. The HRSG is most commonly used in a combined-cycle power station in order to produce electricity.
The cylindrical, elliptical-shaped steam drums have a capacity exceeding fifty liters and are made of steel, with no valves, instrumentation or other mechanical/thermal equipment included. These steam drums are specifically designed for a HRSG, and once installed will serve to separate steam from liquid water.
The steel exhaust stack, which acts as a chimney, is specifically designed to be directly connected to the casing panels by the outlet ducting in the HRSG. The exhaust stack allows the exhaust gas to circulate out of the boiler.
The module boxes are strictly heat exchangers that incorporate header pipes, finned or bare tubes, tube sheet plates, casing seals, duct and casing assemblies, which are all supported by steel structural columns mounted on the panels. The heat exchangers, which are designed and connected to the HRSG, transfer energy from turbine exhaust gas to heat water internal to the pressure parts in order to produce steam.
The steel inlet duct panel assemblies incorporate a liner plate, casing plate, insulation, studs, and all connecting elements. The assemblies will be supported by steel structural columns mounted onto the panels of the HRSG. They are designed and constructed specifically for the HRSG in order to evenly guide and transfer turbine exhaust gas from the turbine discharge thru the pressure parts and across the selective catalytic reactor (SCR) and duct burner.
The applicable subheading for the Heat Recovery Steam Generator (HRSG) parts (steam drums, exhaust stack, and inlet duct panel assemblies) will be 8402.90.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Steam or other vapor generating boilers; super-heated water boilers; parts thereof: Parts: Other.” The rate of duty will be 4.3 percent.
The applicable subheading for a Heat Recovery Steam Generator (HRSG) part (heat exchangers) will be 8402.90.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Steam or other vapor generating boilers; super-heated water boilers; parts thereof: Parts: Heat exchangers.” The rate of duty will be 4.3 percent.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Denise Faingar at (646) 733-3010.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division