NY N351978

In your letter dated June 1, 2025, you requested a tariff classification ruling. Technical information was provided with your submission.

The Compression Process Module Train A is a prefabricated structure designed to be installed at a Liquid Natural Gas plant. The tiered module contains two multi-stage centrifugal compressors, oil and process coolers, and piping that features various instrumentation and valves that connect the module to other equipment in the train. The primary function of the module is to increase the pressure of gas mixtures containing methane and nitrogen.

The applicable subheading for the compression module will be 8414.80.2015, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Other, except parts: Other compressors: Other: Centrifugal and axial. The general rate of duty will be Free.

You indicate the module may be from China. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty.

At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheading 8414.80.2015, HTSUS, listed above.

Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheading 8414.80.2015, HTSUS, listed above.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8415.80.2015, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheadings 8414.80.2015, HTSUS, listed above.

It is also mentioned that the module may be from India. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of India will be subject to an additional ad valorem rate of duty of 25 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.02.26, in addition to subheading 8414.80.2015, HTSUS, listed above.

The tariffs and additional duties cited above are current as of this ruling’s issuance.

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 Sandra Martinez at sandra.martinez@cbp.dhs.gov.

Sincerely, (for)

James Forkan Acting Director National Commodity Specialist Division