NCS/ARS/CL/10353

We have received your request for the tariff classification of a Halliburton VCH Versa-Trieve® Packer, for which you have proposed a tariff classification under the Harmonized System Code 84.79.89.00.00 as, 'Other, Machines and mechanical appliances having individual functions, not specified or included elsewhere in this Chapter.’

PRODUCT DESCRIPTION AND ANALYSIS 

The packer sealbore is a sealing device that isolates and contains produced fluids and pressures within the tubing string; it is a well barrier element, usually part of the well's primary well barrier, protecting the casing and creating an A-annulus. The packer is essential to the basic functioning of most wells, injectors or producers.  A  sealbore retrievable packer creates a tight seal that stands up to wellbore loads.

In addition to providing a seal between the tubing and casing, other aspects of a packer are as follows:

• Prevent downhole movement of the tubing string, generating considerable axial tension or compression loads on the tubing string.
• Support some of the weight of the tubing where there is significant compressive load on the tubing string 
• Allows the optimum size of well flow conduit (the tubing string) to meet the designed production or injection flowrates
• Protect the production casing (inner casing string) from corrosion from produced fluids and high pressures
• Can provide a means of separating multiple producing zones
• Provided the tubing string and packer maintain integrity, well control is focused on the tubing flow, allowing the downhole safety valve to shut-off flow from the reservoir. 
• Hold well-servicing fluid (kill fluids, packer fluids) in the casing annulus.
• Facilitate artificial lift, such as continuous gas lifting through the A-annulus.  

Packers have four key features:

• Slip
• Cone
• Packing-element system
• Body or mandrel.

The slip is a wedge-shaped device with wickers (or teeth) on its face, which penetrate and grip the casing wall when the packer is set. The cone is beveled to match the back of the slip and forms a ramp that drives the slip outward and into the casing wall when setting force is applied to the packer. Once the slips have anchored into the casing wall, additional applied setting force energizes the packing-element system and creates a seal between the packer body and the inside diameter of the casing.

Production packers can be classified into two groups:

• Retrievable: It can be removed from wellbore without milling and are re-usable.
• Permanent: Permanent packers can be removed from the wellbore only by milling

According to your supporting documents, The Halliburton VCH Versa-Trieve® Packer is a Versa-Trieve barrel slip packer with a Versa-Latch top sub. The Versa-Trieve families of packers are retrievable, single-bore packers with a single set of Slips below the element package. The Versa-Trieve Line of packers as well as some permanent seal bore packers have similar functional features that can be set to provide an anchor point in the well casing and has a polished mandrel that acts as a seal bore for a seal assembly. It also provides an upper connector for attachment to seal unit locators. It features a Spring-loaded, case carburized internal locking slips maintain maximum element compression.

TARIFF CLASSIFICATION DECISION

The Explanatory Notes (EN) section  (C ) to tariff heading 84.84 describes mechanical seals as ; Mechanical seals (e.g., sliding-ring seals and spring-ring seals) constitute mechanical assemblies which form a leakproof joint between flat, rotating surfaces to prevent high-pressure leakage in the machine or apparatus on which they are mounted, resisting the pressure and stress exerted on them by moving components or due to vibrations, etc.

The structure of these seals is generally fairly complex. They comprise:

(i)    fixed parts which, when the seal is placed, become integral with the machine or apparatus; and

(ii)   movable parts: rotating elements, spring elements, etc.

The Halliburton VCH Versa-Trieve® Packer is a sealbore retrievable packer comprising of both moveable and immovable parts with spring seals in line with the descriptions in the EN above. It is therefore appropriately classified in tariff heading 84.84.20.00.00 as, ‘Gaskets and similar joints of metal sheeting combined with other material or of two or more layers of metal; ….  Mechanical seals', with a duty rate of 10% and 0% VAT in line with the provisions of the ECOWAS CET 2022 - 2027.

Legal Framework and Justification

GIR 1 and 6