NCS/ARS/CL/10434

You have applied for the tariff classification of the following products, imported as fully built units (FBUs):

1. CDR 850 ASME AC – Twin-Tower Desiccant Air Dryer; 
2. OTM TDR850 – Compressed-Air Aftercooler; and 
3. XAMS 850 SQE G3 – Diesel-Powered Screw Air Compressor.

PRODUCT ANALYSIS

1. CDR 850 ASME AC

According to the submitted documentation, the CDR 850 ASME AC is identified as Atlas Copco portable twin-tower desiccant air dryer designed for the continuous removal of moisture from compressed air. The unit is equipped with ASME-coded pressure vessels and has a rated air flow capacity of approximately 850 cfm.

The equipment operates on the principle of adsorption, whereby moisture contained in compressed air is removed by a desiccant material, such as activated alumina or silica gel. The dryer consists of two desiccant-filled towers that operate alternately. While compressed air passes through one tower, the desiccant in that tower adsorbs moisture from the air. Simultaneously, the second tower undergoes a regeneration cycle to remove the moisture accumulated in its desiccant. The towers subsequently switch functions, thereby providing a continuous supply of dry compressed air.

The CDR 850 is designed to achieve a pressure dew point of approximately –40°C (–40°F). Its self-contained pneumatic control system enables the drying and regeneration cycles to operate without an external AC electrical power supply. The equipment is principally designed as a dedicated apparatus for drying compressed air rather than for generating or compressing air.

2. OTM TDR850

The TDR 850 is an aftercooler designed to reduce the temperature of compressed air after it leaves an air compressor. It incorporates an aluminium block cooling element with finned surfaces to facilitate heat transfer.

A pneumatically driven fan, fitted with a protective guard for operator safety, forces ambient cooling air across the cooling fins, thereby dissipating heat from the compressed air. This arrangement provides efficient cooling while maintaining relatively low energy consumption.

The aftercooler is mounted on a protective crash frame for durability and ease of handling. The units are supplied with wall-mounting brackets to facilitate installation and fitted with a manual condensate drain valve for the removal of moisture formed during the cooling process.

3. XAMS 850 SQE G3

According to the submitted documentation, the XAMS 850 SQE G3 is an Atlas Copco portable diesel-powered screw air compressor designed to generate and supply compressed air for heavy-duty industrial applications.

The unit has an approximate air delivery capacity of 24 m³/min (850 cfm) at a working pressure of approximately 8.6 bar (125 psi). It incorporates a rotary screw compression system driven by a diesel engine and is designed for mobile operation at locations where a stationary compressed-air supply or external electrical power may not be available.

The XAMS 850 SQE G3 is suitable for demanding applications such as mining, drilling, construction, quarrying and abrasive blasting, where a continuous supply of compressed air is required for the operation of pneumatic equipment and processes.

Accordingly, the products perform distinct principal functions: the CDR 850 ASME AC is principally designed for the drying of compressed air; the OTM TDR850 is an aftercooler designed to reduce the temperature of compressed air; while the XAMS 850 SQE G3 is principally designed for the compression and supply of air.

TARIFF CLASSIFICATION

Based on the description and analysis of the products, their classification is determined as follows:

1. CDR 850 ASME AC – Desiccant Air Dryer

The CDR 850 ASME AC is a compressed-air treatment unit principally designed to remove moisture from compressed air, thereby producing dry, purified compressed air suitable for downstream industrial and pneumatic applications. Its essential function is therefore that of drying and purifying compressed air.

Heading 84.21 covers: “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof.”

Furthermore, the Explanatory Notes to Heading 84.21, Part (II)(B), covers “Filtering or purifying machinery and apparatus for gases,” that Such equipment may operate by various physical or mechanical principles to remove solid or liquid particles and other undesirable constituents from a gas stream.

Accordingly, having regard to the principal function and objective characteristics of the equipment, the CDR 850 ASME AC is appropriately classified under tariff subheading 8421.39.90.00 – Filtering or purifying machinery and apparatus for gases: Other, at 5% rate of duty and 0% VAT, in line with ECOWAS Common External Tariff (CET), 2022–2027, GIR 1 and 6, and Explanatory Notes to Heading 84.21, Part (II)B.

2. OTM TDR850 – Compressed-Air Aftercooler

The OTM TDR850 is an aftercooler designed principally to reduce the temperature of compressed air discharged from an air compressor. The unit employs an aluminium cooling element and a pneumatically driven fan to dissipate heat from the compressed air.

The Explanatory Notes to Heading 84.19, paragraph 2, cover machinery and plant designed to subject materials, whether solid, liquid or gaseous, to a heating or cooling process in order to effect a simple change in temperature or a transformation resulting principally from a change in temperature.

Accordingly, OTM TDR850 is properly classified under tariff subheading 8419.50.00.00 – Heat exchange units, at 5% rate of duty and 0% VAT in line with ECOWAS Common External Tariff (CET), 2022–2027, GIR 1 and 6, the Explanatory Notes to Heading 84.19, paragraph 2.

3. XAMS 850 SQE G3 – Portable Air Compressor

The XAMS 850 SQE G3 is a portable, diesel-powered screw air compressor designed to generate and supply compressed air for heavy-duty applications, including mining, drilling, construction and abrasive blasting.

In accordance with the provisions of Part (A) of the Explanatory Notes to Heading 84.14, air and gas compressors, including compressors designed for various industrial applications, are covered by heading 8414.

However, given that the principal function of XAMS 850 SQE G3 is to compress and supply air, the product falls within the scope of Heading 84.14, which covers:

“Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; and gas-tight biological safety cabinets, whether or not fitted with filters.”

Accordingly, XAMS 850 SQE G3 is properly classified under tariff subheading 8414.40.00.00 – Air compressors mounted on a wheeled chassis for towing, at 10% Rate of duty and 0% VAT, in accordance with ECOWAS Common External Tariff (CET), 2022–2027, GIR 1 and 6, the Explanatory Notes to Heading 84.14, Part (A).

LEGAL JUSTIFICATION

• GIR 1&6
• Explanatory Notes to Heading 84.21, Part (II)B
• Explanatory Notes to Heading 84.19, paragraph 2
• Explanatory Notes to Heading 84.14, Part (A)