CLA-2-84:RR:E:NC:1:120 R05112
Mr. Joseph Veiga
6709 Summit Ridge Drive
Watauga, TX 76148
RE: The tariff classification of oxidizer products imported from China
Dear Mr. Veiga:
In your letter dated October 25, 2006 you requested a tariff classification ruling on behalf of Megtec Systems, Inc.
The products under consideration are Regenerative Thermal Oxidizers (RTO) and Recuperative Thermal Oxidizers (RCO). Thermal oxidizers are used as a method of pollution control for process air containing small particles of combustible solids or liquids. They destroy air toxics and Volatile Organic Compounds (VOCs) that are discharged in industrial process exhausts.
The RTO imported models: Cleanswitch, Enterprise II, and Millennium system have a ceramic fiber-lined, steel outer skin and an access platform for servicing burner components. Through the process of high temperature thermal oxidation, VOCs are converted to carbon dioxide and water vapor, recycling released energy. These models use ceramic heat transfer beds as heat exchangers, coupled to a retention chamber where the organics are oxidized to recover as much energy as possible (90-95%) from the oxidation process.
The RCO imported models: Katec and Ventura have a ceramic-lined steel outer skin with access to all internal parts. During the RCO operation, VOC-laden air is drawn into the system fan and is discharged into the system’s heat exchanger. The air is preheated through the tube side of the heat exchanger and then passes the burner, where the contaminated air is raised to the thermal oxidation temperature for the specified residence time to effect an exothermic reaction. The VOCs in the air stream are converted to carbon dioxide and water vapor. The hot, purified air then passes on the shell side of the heat exchanger where the energy released by the reaction is used to preheat the incoming air. The heat exchanger minimizes the system’s fuel consumption and the contaminant free air is exhausted into the atmosphere.
The applicable subheading for the Cleanswitch, Enterprise II, Millennium, Katec and Ventura will be 8421.39.8030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus for gases: Other: Other: Other: 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 Denise Faingar at 646-733-3010.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division