CLA-2-84:OT:RR:NC:N1:102
Zachariah Parsons
ZF North America, Inc.
15811 Centennial Drive
Northville, MI 48168
RE: The tariff classification of a heat exchanger from Germany.
Dear Mr. Parsons:
In your letter dated April 14, 2015 you requested a tariff classification ruling.
The “After Cooler”, part number K-32997-02, is described as a steel heat exchanger for the Ipsen G-2000-ENT Endothermic Gas Generator. The Ipsen G-2000-ENT Endothermic Gas Generator produces gas, which is used for the heat treatment of metal parts. The gas production involves many processes, to include passing an air-gas reaction above a catalyst enclosed in a pressured retort, where temperatures range between 925-1200 degrees centigrade. The air-gas mixture is then circulated through a heat exchanger. The heat exchanger consists of two parallel series of baffle plates that are interconnected by narrow chambers. Cooling water flows in separate tubes within the exchanger, absorbing the heat through the baffle plates. This drops the temperature of the air-gas mixture, while simultaneously increasing the temperature of the water. The “After Cooler” measures 73.23 inches by 11 inches and weighs 50 pounds.
In your letter, suggested is subheading 8419.90.9580, 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 change of temperature such as heating, cooking, roasting…Parts; Other. Based on the diagram provided and the description of the item, the “After Cooler” is a heat exchanger, rather than a part of a heat exchanger, as suggested. Therefore, subheading 8419.90.9580, HTSUS, is precluded.
As such, the applicable subheading for the “After Cooler”, part number K-32997-02, will be subheading 8419.50.5000, 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…Heat Exchange Units; Other. The 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 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 Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division