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NY N024281




April 4, 2008

CLA-2-84:OT:RR:NC:1:120

CATEGORY: CLASSIFICATION

TARIFF NO.: 8421.29.0065, 8421.99.0080

Ms. Sarah M. Nappi
Latham & Watkins LLP
555 Eleventh Street N.W.
Suite 1000
Washington, D.C. 20004

RE: The tariff classification of Trays, Structured Packing, Random Packing and Mist Eliminators from various countries

Dear Ms. Nappi:

In your letter dated March 5, 2008 you requested a tariff classification ruling.

The merchandise under consideration includes Trays, Structured Packing and Random Packing, and Mist Eliminators. They are physically located in processing towers, distillation columns, tanks and piping systems to facilitate the separation of liquids and gases.

The Trays are regularly spaced horizontal decks, with openings, arranged within a column tower to provide a surface on which the ascending and descending liquids can coalesce without inhibiting the ascending vapor flow. Such equilibrium stages may also be referred to as a theoretical tray. The performance of many separation processes depends on having a series of theoretical trays and is enhanced by providing more such stages. In other words, having more theoretical plates increases the efficiency of the separation process. They are available in any formable, weldable sheet metal material such as: carbon steel, stainless steel, ferritic, austenitic, duplex, martensitic, nickel alloys, copper alloys, titanium, and zirconium.

The Structured Packing is constructed of sectional layers of only corrugated thin metal or plastic sheets. This ruling does not cover any packing made of ceramic, which is excluded from classification in Chapter 84, Section XVI of the Harmonized Tariff Schedule of the United States. It is regularly spaced in a precise manner in the column tower to provide a large surface area upon which the contact between the ascending vapor and descending liquid can occur for heat and mass transfer in the separation process. It offers a higher capacity than Random Packing or conventional trays to increase separation efficiency.

The Random Packing is discrete pieces of formed metal or molded plastic that combines saddle shape to ring type packing. Unlike the structured type, it is randomly thrown in the column tower to provide additional surface area upon which the contact between the ascending vapor and descending liquid can occur during the separation process. The tower packing reduces pressure drop through the column, increases the capacity compared to trays and reduces the liquid holdup in the column.

Mist Eliminators are located in the tower to filter liquid droplets from gas streams. They are constructed of a wire mesh screen or packed fiber construction, baffled layers or concentric tubular surfaces to separate and drain liquid particles. Specifically, a vapor stream carrying the entrained liquid droplets passes through a mist eliminator. The inertia of the droplets causes them to contact the surfaces and coalesce. The large, coalesced droplets formed in the mesh ultimately drain and drop to the vessel bottom.

The applicable subheading for the Trays, Structured Packing and Random Packing will be 8421.99.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Filtering or purifying machinery and apparatus for liquids or gases: Parts: Other: Other.” The rate of duty will be free.

You requested classification of the Mist Eliminators in subheading 8421.99.0080 or 8421.39.8040. The Mist Eliminators are performing a filtering function. The applicable subheading for the Mist Eliminators will be 8421.29.0065, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Filtering or purifying machinery and apparatus for liquids: 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,

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