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NY N023302

March 4, 2008



TARIFF NO.: 8419.90.9580

Ms. Bridget Moore
WTS of Houston, Inc
15900 Morales Rd.
Houston, TX 77032

RE: The tariff classification of hydrocracking reactor vessels from Italy.

Dear Ms. Moore:

In your letter dated February 7, 2008 on behalf of Hunt Refinery, you requested a tariff classification ruling. You included a description of the item and its operation with your request.

The merchandise at issue are referred to as hydrocracking reactor vessels. The vessels are constructed of alloy steel which is clad in stainless steel according to your explanation of the submitted metallurgical specifications. This composition is to assure that the vessels withstand the high pressure of the hydrocracking process. The vessels are a part of a larger catalytic system which rectifies crude oil products into lighter products. The reactions take place in these vessels while under pressure with the addition of hydrogen and the introduction of a catalyst which will produces heat within the vessel for separation of oil products.

You suggest that the hydrocracking reactor vessels would be correctly classified as other machinery, plant or equipment: other: other, other: for other materials in 8419.89.9585 Harmonized Tariff Schedule of the United States (HTSUS). This is not correct as the vessels are to be considered as a part of the system and not capable of operating independently of the other components for the purpose intended.

The applicable subheading for the hydrocracking reactor vessels will be 8419.90.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for machinery, plant or laboratory equipment, whether or not electrically heated, for the treatment of materials by a process involving a change of temperature such asrectifying,: parts: other: other, other. The general rate of duty will be 4 percent ad valorem.

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 Mark Palasek at 646-733-3013.


Robert B. Swierupski

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