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NY 866256


SEP 17 1991

CLA-2-84:S:N:N1:105 866256

CATEGORY: CLASSIFICATION

TARIFF NO.: 8419.89.5075

Mr. Edward L. Hart, Jr.
Lee Hardeman Customs Broker, Inc.
P.O. Box 45545
Atlanta, GA 30320-0545

RE: The tariff classification of a methanol reactor from Germany.

Dear Mr. Hart:

In your letter dated August 8, 1991 on behalf of Hydro-Chem Processing Inc. you requested a tariff classification ruling.

Methanol reactor R-301 is a component of a synthesis loop for producing crude methanol from synthesis gas, which is mostly hydrogen. As the process description you attached states, the synthesis loop also includes an interchanger, air cooler, final cooler and separator. Your letter indicated that all these would be imported, but in telephone conversation with National Import Specialist Michael Rocks of my office, Mr. John Schurek of Hydro- Chem indicated that only the R-301 reactor, excluding even the steam drum V-301, would be imported. All remaining components will be domestically sourced, he stated.

The reactor is tubular, and its tubes will be filled with catalyst before use. The catalyst facilitates an exothermic reaction in which crude methanol gas is separated from the synthesis gas. The heat thus generated is transferred to water circulating around the tubes, thereby causing it to boil and produce steam. This steam is used to power a compressor that initiates the synthesis process.

The crude methanol gas produced in the reactor later passes through an interchanger, an air cooler and a final cooler, each of which successively lower its temperature. Finally, the condensed liquid crude methanol is separated and routed to a distiller. We repeat that only the reactor is being imported.

The applicable subheading for the methanol reactor R-301 will be 8419.89.5075, Harmonized Tariff Schedule of the United States (HTS), which provides for other machinery, plant or laboratory equipment for the treatment of materials by a process involving a change of temperature. The rate of duty will be 4.2 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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