NCS/ARS/CL/10432

We are in receipt of your application for tariff classification of FD5 Refrigerant Dryer and UD75+ Coalescing Compressed-Air Filter, both imported as fully built units.

PRODUCT ANALYSIS

1. FD5 Refrigerant Dryer

Based on the submitted documentation, the FD5 Refrigerant Dryer is designed for the removal of moisture from compressed air for general industrial applications. Compressed air naturally contains water vapour which, if not removed, may negatively affect downstream equipment, production processes and applications requiring dry compressed air.

The FD5 operates on the refrigeration and condensation principle. The drying process may be summarised as follows:

1. Pre-cooling: Warm, moisture-laden compressed air enters the dryer and is pre-cooled in an air-to-air heat exchanger by the outgoing dry compressed air.
2. Refrigeration cooling: The pre-cooled compressed air is subsequently passed through an air-to-refrigerant heat exchanger, where it is further cooled to approximately +3°C (37°F).
3. Condensation: At this reduced temperature, the water vapour contained in the compressed air condenses into liquid water.
4. Condensate removal: The condensed water is automatically discharged through an electronic no-loss drain, thereby removing the moisture from the compressed-air stream while minimising compressed-air losses.
5. Reheating: The outgoing dry compressed air is reheated in the air-to-air heat exchanger by the incoming warm compressed air. This reduces the risk of condensation occurring in downstream piping and equipment.

The FD5 is therefore principally a refrigerant-type compressed-air dryer, whose essential function is to reduce the moisture content of compressed air through cooling, condensation and removal of the resulting condensate.

According to the submitted technical documentation, the FD5 has the following principal characteristics:

• Maximum inlet/ambient temperature at full flow: 60°C;
• Pressure dew point: approximately +3°C (37.4°F);
• Nominal flow rate: 6 L/s (approximately 13 cfm);
• Pressure drops at full flow: 0.07 bar (1.02 psi);
• Maximum working pressure: 16 bar (233 psi);
• Condensate removal: Electronic no-loss drain; and
• Application: General industrial compressed-air systems requiring a pressure dew point of approximately +3°C.
• Functional Assessment

The FD5’s essential function is the removal of water vapour by refrigeration, condensation and subsequent drainage of the condensed moisture.

TARIFF CLASSIFICATION

Having regard to the construction, operating principle and essential function of the FD5, the product is specifically designed to dry compressed air through a temperature-change process involving refrigeration, condensation and condensate removal. 

Also, the Explanatory Notes to Heading 84.19, under Part (VII), provide for specially designed equipment for the treatment of air, including equipment for drying air.

Based on this, the FD5 is appropriately covered by Heading 84.19, which covers

“Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 85.14), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilising, pasteurising, steaming, drying, evaporating, vaporising, condensing or cooling…”

Accordingly, the FD5 Refrigerant Dryer is appropriately classified in tariff subheading 8419.39.00.00 – Other dryers, at 5% rate of duty and 0% VAT, in accordance with the ECOWAS Common External Tariff (CET), 2022–2027, GIR 1 and 6 and Explanatory Notes to Heading 84.19, Part (VII)

2. UD75+ Coalescing Compressed-Air Filter

Based on the submitted documentation, the UD75+ is an Atlas Copco coalescing compressed-air filter designed for the filtration and purification of compressed air. Its principal function is to remove contaminants from a compressed-air stream, particularly oil aerosols, water droplets, wet dust and fine particulate matter, before the air is supplied to downstream equipment or processes.

The filter operates on the coalescing filtration principle, i.e where fine liquid aerosols and suspended contaminants present in the compressed air are captured by the filter media. The small oil and water droplets are caused to coalesce into larger droplets, which are subsequently separated from the air stream and drained. This process substantially reduces oil and liquid carry-over and provides cleaner compressed air for downstream applications.

The UD75+ is installed directly in a compressed-air line and does not generate compressed air. Its function is specifically to filter and purify the compressed-air stream by separating suspended solid and liquid contaminants from the gas.

According to the submitted technical documentation, the UD75+ has the following principal characteristics:

• Type: Coalescing compressed-air filter;
• Nominal flow rate: 75 L/s (approximately 159 cfm);
• Connections: G 1-inch threaded connections;
• Working pressure: 1–16 bar(g) (approximately 14.5–232 psi);
• Dimensions: approximately 580 × 150 × 120 mm;
• Weight: approximately 3 kg;
• Filter medium: Patented glass-fibre media;
• Filtration configuration: Integrated DD+ and PD+ filtration stages in a single housing;
• Pressure drops approximately 0.2 bar (2.9 psi), including when the filter media is saturated;
• Particle removal efficiency: up to 99.999% at particle sizes of 0.01 and 1 micron and approximately 99.94% at the most penetrating particle size; and
• Compressed-air quality: ISO 8573-1 Class 1 for particulate matter and Class 2 for oil.

The UD75+ is principally designed to filter and purify compressed air by removing suspended solid and liquid contaminants, including oil aerosols, water droplets, wet dust and fine particulate matter. 

TARIFF CLASSIFICATION

The UD75+ is specifically designed to separate solid and liquid contaminants from a compressed-air stream, which is a gas. Its coalescing filter media captures oil aerosols, water droplets and particulate matter, thereby purifying the compressed air before it proceeds to downstream applications.

Also, The Explanatory Notes to Heading 84.21, Part (B), relating to filtering or purifying machinery and apparatus for gases, cover various types of filters and purifiers designed to separate solid or liquid particles from gases.

Based on the description and functionalities of UD75+, the product falls under Heading 84.21, which covers: “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus for liquids or gases…” and is properly classified in tariff subheading 8421.39.90.00 – Other filtering or purifying machinery and apparatus for gases, Other, at 5% Rate of duty and 0% VAT, in accordance with the ECOWAS Common External Tariff (CET), 2022–2027, GIR 1 and 6 and Explanatory Notes to Heading 84.21 Part (B).

LEGAL JUSTIFICATION

• GIR 1 & 6
• Explanatory Notes to Heading 84.19, Part (VII)
• Explanatory Notes to Heading 84.21 Part (B)