CLA-2-90:OT:RR:NC:N1:105
Alan Goodbrand Proactive Analytics Unit 2 Vermont Pl, Tongwell Milton Keynes MK158JA United Kingdom
RE: The tariff classification of a fluid pressure system from the United Kingdom
Dear Mr. Goodbrand:
In your letter dated November 20, 2024, you requested a tariff classification ruling.
The item under consideration is the ExiFlo, which is a hardware device that tests the integrity of fluid channels within a heat exchange system. The device identifies leaks between plates and the outside environment without the need to take the system offline. The tests are carried out before and after each production cycle to ensure that each product batch receives a pass or fail certification before leaving for distribution. ExiFlo produces a test result (electronic certificate) informing the user if they have a defect within their heat exchanger that the device is installed into and provides the micro liter reading on a graphical user interface. The ExiFlo can be installed to existing lines with different types of heat exchangers or tanks and provides a quantification of leaks. Additionally, data-driven maintenance information is available in real-time, remotely, or at the module. ExiFlo’s primary task is to measure flow, however, pressure sensors are used internally within ExiFlo as well. The ExiFlo is comprised of a manifold, valves, sensors, a micropump, and electronic printed circuit boards. The device measure 52cm by 45cm by 34cm and weighs 18kg. As you suggest in your letter, the applicable subheading for the Exiflo will be 9026.80.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus for measuring or checking the flow, level, pressure or other variables of liquids or gases (for example, flow meters, level gauges, manometers, heat meters), excluding instruments and apparatus of heading 9014, 9015, 9028 or 9032; parts and accessories thereof: Other instruments and apparatus: Electrical.” 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/.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division