Attachment to Section 301 Exclusion request 

Public Version of BCI 

Re: USTR-2018-0025 — Procedures to Consider Requests for Exclusion of Particular 

Products from the Determination of Action Pursuant to Section 301: 

Request of Gen2 Technologies for Exclusion of Pyrolysis waste tire and plastic processing 

system 

1. IDENTIFICATION OF PHYSICAL CHARACTERISTICS OF 

PARTICULAR PRODUCT THAT DISTINGUISHES IT FROM 

OTHER PRODUCTS IN SUBHEADING 8417.80.0000 

A. Equipment uniqueness description: 

Requestor has acquired processing equipment purchased from mainland China. This 

equipment was purchased from China solely because it is a very unique design of a Pyrolysis waste 

tire and plastic processing system. Pyrolysis as a whole has been in existence for over sixty years 

in the United States and elsewhere. But to date, no equipment manufacturer exists in the United 

States, Northern America or Europe which currently manufactures this very specialized type of 

equipment. As a result, it was necessary for requestor to source this product from outside the 

United State to find equipment that would meet its needs for processing waste tires, and possibly 

waste plastics into a viable oil, or other fuel alternatives. Requestor is bringing this equipment to 

the United States to install it at a facility being acquired in Northern California. Once installed, 

requestor will study this equipment's operational capabilities, improve the design and would then 

intend to build, or have built, future versions of this equipment in the United States with American 

labor and American made steel. As per the narrative stated below and other responses in this 

Exclusion Request, this equipment will enable requestor to be the only company in the United 

States to use and eventually produce this very specialized equipment. This equipment not only 

produces alternative fuels, but it is environmentally friendly due to a closed loop system that does 

not emit VOC's or anything toxic into the environment. As described below, the uniqueness of 

this system is due to an Electrical Induction Heating process designed to balance the heat evenly 

throughout the circumference of the process vessels. The processing vessels also Rotate during 

the processing allowing the waste tire or plastic feed stock inside to heat evenly while not over 

heating some portion of the batch, and under heating other parts of the batch. These two unique 

technology features provided a quantum breakthrough in Pyrolysis equipment design that 

consistently produces a high-grade fuel oil, unlike any other equipment available from any other 

known source. 

Note: There are three specific pieces of hardware that comprise a full production line or 

complete "system". The Primary and Secondary process vessel systems, and related hardware, 

have been designed and produced in China. The third piece of hardware that contains a catalyst 

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has been initially designed by a U.S. based company located in California and Texas. That party 

would be commissioned to build this third specific piece of hardware if the requestor's Exclusion 

Request is granted. If the Exclusion Request is not granted, then requestor will need to search for 

an alternative supplier, possibly outside the U.S., to reduce the cost of this very expensive third 

piece of equipment in order to make the entire system economically viable it the 25% Section 301 

tariff is not waived on the China-made portion of the full production line. 

B. Equipment Name: 

WXT-8 Twin reactor pyrolysis system, consisting of one twin primary vessel processing 

system and one single vessel secondary processing system. 

C. Process description over view: 

A tire or plastic to oil process consisting of a combination of three in-line processes designed to 

operate as one complete system. These processes will be further described throughout the 

narrative. The first system is the Pyrolysis Electrical Induction Heating system, which converts 

waste tires or hard-to-recycle waste plastic feed stock into sweet crude oil. The second system is 

a Secondary distillation process. This system is linked to the Pyrolysis converter which directs oil 

to flow into a secondary process vessel then through its distillation process to further refine the oil. 

This is accomplished through a secondary heat signature for greater oil purity. The last piece of 

equipment is the Catalyst filtration system. Oil sent to this system passes through a proprietary 

catalyst system and is transferred to the finished product storage vessels. 

D. Pyrolysis System from China 

1. Equipment Description: 

The WXT-8 Twin Process Vessel system sourced from China consists of two Rotating 

process vessels operating via an Electrically-Heated Induction process, wherein each reactor 

operates independently. The system is controlled by a semi-computerized process controller that 

monitors heat at two different zones on each process vessel. As the feed stock material temperature 

rises it turns into a vaporous gas which in turn moves through a separation chamber. At the 

separation chamber there are three specific activities that take place: 1) the feed stock liquefies, 2), 

it vaporizes and, 3), passes through a condenser where it is turned back into a liquid fuel oil. This 

high-grade oil, similar to a West Texas Intermediate oil, is the first product. The second product is 

recovered steel. All tires contain steel and it will be sold as high-grade scrap steel. The last product 

that is recovered is Carbon Black, which is a highly sellable commodity. 

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2. Process vessel heating: 

The process vessels are each heated by two Electrical Induction Heating generators. By 

using an electrical induction heating source, and with this proprietary advanced Rotating design, 

there are no emissions, as is the case with other pyrolysis systems heated with natural gas or coal. 

3. Cooling System: 

The Induction Heating Generator and distillation system are cooled by a water-cooling 

system. This system may be one of two types; either a water evaporation system (tower water 

system), or a Chilled refrigerated water system. Either style system is closed looped and has no 

direct contact with vaporized oil, or the other by-products. Consequently, there is no chance of 

water pollution. 

E. Handling of finished product and by-products: 

Three specific by-products result from the processing of waste tires, and or waste plastic 

feed stock. The first is a high-quality Oil. Feedstock is heated to a specific temperature to vaporize 

the material, and then it is subsequently distilled into oil. The oil is processed through the 

distillation process that is a closed loop system without any outlets thereby preventing any 

possibility of leaking gases, or VOC vapors, as emissions. The second is recovered Carbon Black, 

or char, which is the residual of the feedstock remaining after the conversion process. The third is 

a compressible gas which is not distilled during the oil distillation process. The "Produced gas" 

passes through gas scrubbers and is converted to LPG-like gas. This gas will be used to assist in 

fueling other waste plastic processing systems being procured by the requestor which are not the 

subject of this Exclusion Request. If waste tires are used as feedstock, a fourth by-product occurs, 

which is steel remaining in the primary process vessels after the entire process completes its cycle 

and has cooled to ambient temperature. 

F. Conclusion; 

The construction of the entire proprietary pyrolysis conversion system is designed to completely 

eliminate the possibility of any vapors, gases, or odors, being emitted to the atmosphere. All EPA 

emission guides will be strictly adhered to. 

G. Equipment Hardware; 

All Motors, temperature controllers, timers and switches are CE certified. All pressure vessels are 

ASTM rated and have been, or will be, pressure tested to a proof-pressure as per ASTM 

requirements. Flanges and Valves will meet ASTM standards. 

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1. Secondary Distillation System; 

The system's Secondary Distillation System has an Electrically-Heated Induction system 

similar to the Primary Pyrolysis Reactor system. The Secondary distillation system is utilized to 

further refine the oil into a high-grade and marketable oil by processing it through a secondary 

heating process. 

The Secondary Distillation system is a closed looped system. The entire system has been 

tested for any emission leaks. No emission leaks were found. 

2. Catalyst Filtration System; 

The Catalyst filtration system is specifically designed to remove residual Organic Chloride. 

The system will again be a closed loop system that has zero emission. This equipment has been 

designed by a United State based company. Should the Exclusion Request be granted, this party 

will construct the Catalyst filtration system in the United States, using American labor and 

American made Steel. If the Request is not granted, requestor may be forced to locate an 

alternative, lower-cost supplier possibly from a 3rd country to make the entire production line 

economically feasible. 

2. 10 DIGIT SUBHEADING OF HTSUS FOR PARTICULAR 

PRODUCT REQUESTED 

The product to be imported for which a Section 301 Exclusion is being requested has 

been classified under Tariff No. 8417.80.000 per a Ruling issued by U.S. Customs and Border 

Protection to a freight forwarder for a separate company from which the requestor has a license 

to purchase and use such Twin Pyrolysis Reactor Systems from China. A copy of that Ruling is 

attached as a separate item to this Section 301 Exclusion Request. 

Based upon information provided by the Chinese manufacturer, neither the licensor who 

received that Ruling, nor anyone else, has ever purchased or imported such a system into the 

United States prior to the requestor, which has now purchased and is importing such a Twin 

Pyrolysis Reactor System for the first time. The System is expected to be imported at the Port of 

Oakland, California sometime during the second week in October, 2018. 

3. DOES THIS SUBMISSION INCLUDE ADDITIONAL 

ATTACHMENTS? 

Attached is CBP New York Ruling N232057 of September 21, 2012. 

This ruling is considered Public Information. 

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4. IS THE CHINESE-ORIGIN PRODUCT OF CONCERN SOLD 

AS FINAL PRODUCT OR AN INPUT USED TO PRODUCE 

THE FINAL PRODUCT OR PRODUCTS? 

The Chinese-origin product for which the Section 301 Exclusion Request is made is an 

"inpur used in the production of the final products to be made with this Twin Pyrolysis Reactor 

System. Primarily waste tires, but also some waste plastic materials, will first be placed in the 

Twin Pyrolysis wherein they will be heated to over I J degrees Fahrenheit in a close-loop 

system with no emissions using Rotating vessels and a specialized Electrical Induction 

Heating apparatus at which point the feed stock becomes molten, and then vaporizes. Those 

vapors are then distilled by means of an integrated distillation system which is also part of the 

imported unit. The product coming from the primary reactor system is a light sweet oil, with 

some heavy oil. The heavy oil is fed back into the primary system to convert it to the light sweet 

oil. The light sweet oil is then conveyed into a secondary distillation system which is also part of 

the imported complete system. Therein the oils are heated again and then distilled down into 

light sweet crude oil to further improve the quality of the high-grade oil. This oil is then stored 

and is to be sold under an existing contract to a major U.S. oil refinery. In addition to the oil, 

the other two products coming out of the Chinese-origin equipment with waste tires as the feed 

stock are recycled Carbon Black and high-grade scrap steel. A small amount of "Producer's gas" 

is also a by-product which will be used by the requestor to power other production equipment at 

its facility which is not the subject of this Exclusion Request. All three products - the light sweet 

crude oil, recycled Carbon Black and high-grade scrap steel - are to be sold, with no residual 

materials left over. Therefore, the Twin Pyrolysis Reactor System which is the subject of this 

Exclusion Request yields a "true end of life to waste tires and hard-to-recycle waste plastics 

thereby preventing those ever-growing items from going to our landfills or being burned creating 

emissions and other harmful impacts to our environment. 

If waste plastics are used as feed stock in the same equipment, the process follows the same 

path. The only difference is that the single salable product is the light sweet crude oil, along with 

a small amount of "Producers gas" which will be used to power other equipment at the 

requestor's site. Again, there will be no residual materials remaining. 

The imported system will meet U.S. safety codes. The Chinese-origin system, as well as the 

add-on equipment that is planned to be U.S. made equipment if the Exclusion Request is granted, 

are all part of a closed-loop production line that produces these end products without any 

emissions or residual materials. The systems, piping, valves, holding tanks and distribution 

system for the oil will all meet U.S. oil and gas industry specifications and safety standards. End 

products will be transported by independent carriers certified to transport such materials. 

FOR IMPORTS OF 'INPUT PRODUCTS USED IN PRODUCING A FINAL PRODUCT 

OR PRODUCTS, PROVIDE THE % OF GROSS SALES IN 2017 WHICH INCORPORATE 

THE USE OF SUCH CHINESE-OR1GIN "INPUT" EQUIPMENT. 

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There were no sales made in 2017 in the United States with such a Twin Pyrolysis Reactor 

System since there were no such systems physically in the United States. And there will not be 

any sales of such products in the United States until this first system is imported in early 

October, 2018. 

This first imported system will be installed in late 2018 at a facility in California which is 

under contract to be purchased. Starting in late 2018, or early during the first quarter of 2019, 

this system will be fully installed, with the assistance of a technical team brought to California 

by the Chinese manufacturer. It will be fully tested before signoff. During the testing and 

throughout on-going production following installation, 100% of all waste tires, or certain waste 

plastic feed stock materials, will be processed with this equipment to make all end products. 

This would also be the case with any future waste tire conversion systems which are already 

planned to be built once this first system is operational. 

5. WHETHER PARTICULAR PRODUCT REQUESTED FOR 

EXCLUSION IS ONLY AVAILABLE FROM CHINA OR 

STRATEGICALLY IMPORTANT TO CHINA 

A. Whether Comparable Product is Available from Sources in the 

United States 

Over the past 6+ years including up until now, the requestor's technical expert and VP of 

Operations has conducted extensive and on-going interne research. He has also continued to 

regularly communicate with industry experts around the world knowledgeable in conversion 

technologies for waste tires and plastics utilizing pyrolysis processes. To date he has not been 

able to locate a source within the United States which could produce a system with the unique 

and extremely important features of the Twin Pyrolysis Reactor System from China which can 

consistently produce high quality oil and carbon black products from waste tires or waste plastic 

Therefore, the system which is the subject of this Exclusion Request is not available from 

sources in the United States, despite the many advantages of buying a locally produced system 

with better local service, materials standard in the U.S., more readily available spare parts, lower 

delivery costs, technical support and documentation in English, etc. 

6. Whether Comparable Product is Available from Sources from 

other Third Countries 

Once again from 6+ years of extensive and on-going internet research plus on-going 

discussions with industry experts in converting waste tires and plastics with pyrolysis processes, 

the requestor's technical expert and VP of Operations has not been able to locate a source in 

another country 3rdCountry which has the unique and extremely important features of the Twin 

Pyrolysis Reactor System from China which can consistently produce high quality oil and carbon 

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black products from waste tires and waste plastic. Therefore, the system which is the subject of 

this Exclusion Request in not available from sources in other Third Countries except China. 

7. ANNUAL QUANTITY AND VALUE OF CHINESE-ORIGIN 

PRODUCT PURCHASED IN LAST 3 YEARS 

Neither the requestor, nor anyone else according to the Chinese manufacturer, has ever 

purchased and imported into the United States such a Twin Pyrolysis Reactor System. The first 

such System is being purchased by the requestor, and it is scheduled to be imported into the 

United States through the Port of Oakland, California sometime during the first two weeks of 

October, 2018. This first-of-its-kind product is being delivered in eleven 40-foot containers. 

The total purchase price and value of this first system is US [ J. 

8. ADDITIONAL INFORMATION 

A. Whether the Particular Product is Strategically Important or 

related to "Made in China 2025" or other Chinese Industrial 

Programs. 

Similar systems to the one subject to this Exclusion Request are used in China by private 

parties to convert a very small amount of waste tires and plastics. But with the vast population 

and growing use of autos, trucks and equipment with tires, plus the vast amount of plastic 

produced and used there, as well as being imported into China, use of such systems cannot even 

deal with even a small fraction of 1% of those materials. There is no government sponsored 

program to support or increase the use of such systems according to the manufacturer. In 

addition, the company producing these systems is a very small company versus the tens of 

thousands of large companies in China, many of whom are supported by the government. 

Consequently, requestor believes a system like this cannot be strategically important to the 

Chinese government. Otherwise this company would be approached by and somehow supported 

by the Chinese government due to the growing accumulation of waste tires and plastics in that 

country. Finally, this product is not remotely associated with any of the items included on the 

Chinese MIC Priority List or the Made in China 2025 List. Consequently, the product subject to 

this Exclusion Request cannot be deemed a high priority to the Chinese government. 

B. Whether Imposition Of Additional Duties On Particular 

Product Causes Severe Economic Hardship On Requestor Or 

Other U.S. Interests 

The requestor is a start-up company whose sole funding comes from a number of private 

U.S. citizens. The particular product, or system, which is the subject of this Exclusion Request is 

the first unit acquired by the requestor. Additional U.S. made equipment still needs to be 

purchased, installed and connected to the system being imported from China to complete the 

entire production line. No revenues will be available until the complete production line is 

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installed and tested which had been planned to be completed during the first quarter of 2019. 

However, that timing is now in serious jeopardy due to the imposition of the 25% Section 301 

tariff on this China made equipment which is classified under subheading 8417.80.0000. 

This completed production line with the addition of the U.S. made special processing 

equipment will be the first of its kind in the world. This full-scale production line will be used to 

prove that these lines are capable of converting waste tires directly into high-grade oil, recycled 

carbon black and scrap steel on an economic basis such that the sale of all those products will 

yield a reasonable profit margin and return for investors. Once that is accomplished, the original 

investors and many other U.S. investors are in place to provide the huge amount of additional 

capital needed to buy and install many more similar systems in multiple, key locations 

throughout the United States and North America allowing the requestor to create hundreds of 

full-time jobs in many locations. 

This production line, as well as future lines, are designed to be closed-loop systems with no 

emissions or negative environmental impacts. Nothing will remain of the tires converted in these 

systems, creating a "true end of life, thereby diverting those tires from going to landfills or 

being burned or improperly disposed. In addition, the energy contained in the high-grade oil 

derived from this process will be equivalent to over 6 times greater than the amount of energy 

used to convert the tires. The annual capacity of each such production line will be approximately 

500,000 passenger tires, or 100,000, 18-wheel truck tires. The systems can also convert large 

tires, as well as hard to recycle plastics which would create only high-grade oil. The requestor 

has a contract in place with one of the large U.S. oil companies to buy all of high-grade oil 

produced from such systems around the United States. This company will blend this 

"recapturecr oil with its other processed crude oil to produce fuels and other finished products, 

thereby reducing its need for the equivalent amount of new crude oil. 

The first system will be located at a property in Northern California which is currently under 

contract to be purchased. The requestor plans to hire 18-20 new direct employees to operate one 

such production line with an annual salary of approximately $1.7 million. Once the first system 

is completed and operational, the requestor intends to acquire and install 2 more production lines 

at this same site within less than one year. This would boost employment to 40-42 direct 

employees with annual salary estimates of $3.7 million. Shortly after that, the requestor would 

plan to acquire 2 more systems for this site boosting employment to 85-90 direct employees with 

annual salary estimates of over $6.7 million. A 5-system plant will be capable of converting 

about 2.5 million waste passenger tires, or 0.5 million 18-wheel truck tires annually, or some 

combination thereof. 

If this first system is successful, which the requestor is very confident it will be, then 

requestor has plans to open a minimum of 7 plants at various key locations around the United 

States during the next 2-4 years. Each would be 5 or 6-system plants or even larger depending 

upon the amount of waste tires available within reasonable transport distances. Each such plant 

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will require a minimum of 80 and possibly up to 120 new direct employees depending upon the 

number of conversion production lines. Consequently, over the next 3-4 years, the requestor 

expects to hire between 550 to 850 new employees if this process proves to be economically 

feasible which requestor expects. But that was before implementation of the Section 301 tariff 

which raises the cost of these systems so much that it might well jeopardize economic success if 

oil prices drop even a small amount. 

The purchase price of the Chinese-made system is $[ 1 so the Section 301 additional 

tariff is $ [ 1. Additional U.S. made equipment costing approximately $1 I still 

needs to be purchased, installed and connect to the Chinese-made product, thus making the total 

system cost around $1 I. The private funding raised in late 2017 to purchase and install 

this initial production line prior to ordering the Chinese-made equipment was $[ I. This 

amount included some contingencies, but nowhere near anything like the 25% additional tariff 

amount. Consequently, if the requestor is not able to obtain an exclusion from the Section 301 

tariff, it will be forced to either find lower-cost, alternative equipment sources, including perhaps 

non-U.S. sources, to complete the production line or raise more equity capital to pay for this 

unexpected tariff increase. Both of these alternatives are very problematic and could jeopardize 

the entire project. Especially since this system was ordered in December 2017 long before there 

was any public discussion of tariff increases on Chinese products. Thus, the impact of requiring 

the "penalty tariff to be paid on this Chinese-made product could actually reduce U.S. jobs 

instead of increasing them. 

According to the Chinese equipment manufacturer, the requestor is the only party to have 

imported one of these system to the United States. Under a signed Letter Agreement between 

the requestor and the Chinese manufacturer, it is the intent of both parties that the requestor will 

soon be granted "an exclusive license for North America to acquire and install its own units, and 

also to sell units to 3rdpartiee. Per the Letter Agreement, the requestor will obtain an Exclusive 

License once it has paid for [ J systems at which time it would be in control of this technology 

throughout North America. However, due to issues the Chinese equipment manufacturer 

encountered in sourcing key components from third parties in China to comply that needed to 

comply with U.S. regulations, plus the high cost of transporting such systems to the U.S. and 

importing them, the requestor and the Chinese manufacturer have already discussed accelerating 

this Exclusive License agreement such that the requestor could make these systems in the U.S. 

and pay a royalty to the Chinese technology supplier. In fact, the CEO of the Chinese 

manufacturer plans to meet with the requestor's management team when the first system is being 

installed in California late this year to reach agreement on such a license. If successful, future 

systems would be built in the U.S. by the requestor for use in North America, using American 

labor and American made steel. This should result in lower overall system costs and also allow 

the requestor to use and sell even more systems to third parties in the U.S., as well as Canada and 

Mexico. Making these systems in the U.S. would create additional new jobs either at a division 

of the requestor, or with a U.S. 3rdparty. 

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Even with a possibility of obtaining a near term license to make future systems in the U.S., 

adding another $I J to the cost of this first production line will make the profitability of 

that system much lower than forecasted for the investors. Possibly so low that the requestor may 

have difficulty convincing existing investors, or others, to contribute additional capital to 

implement its large multi-site, multi-system roll out plans. At a minimum having to pay this 

extra cost will delay those roll out plans for a number of months to a year, thereby delaying the 

hiring of hundreds of people contemplated under the requestor's expansion plans. Payment of 

this Section 301 tariff on this first system at such a critical stage in this startup's history will 

delay, or perhaps jeopardize, job growth which is counter-productive to our Nation's job growth 

objective. It will also delay, or potentially jeopardize, the requestor's mission which is to 

implement a "true end of life, environmentally-friendly solution to America's ever-growing 

waste tire problem, which is shared concern for neighboring countries and many other countries 

around the world. 

We therefore respectfully ask that this Exclusion Request be granted so that this very sizable 

amount of money to a fledgling startup company like the requestor can instead be quickly 

invested to complete this initial production line and hire its first 18-20 employees. This will 

allow the requestor to process upwards of 500,0000 waste tires into salable high-grade oil, 

recycled carbon black and scrap steel in an environmentally-friendly way wherein those products 

can be productively reused in the U.S., while at the same time divert those tires from going to 

landfills. 

We are confident that this system will operate as planned. Therefore, we are equally 

confident that eliminating the extra 25% tariff on this system will be a wise investment for our 

Nation as it will allow the requestor to implement its plans to set up many plants with many 

systems throughout the United States, thereby creating hundreds if not thousands of jobs over the 

next 3-4 years. And at the same time processing millions of tires each year instead of them 

going to landfills. 

C. Ability Of U.S. Customer And Border Protection To 

Administer Exclusion 

Requestor believes that its customhouse broker, Mr. Michael Ramirez of Mainfreight San 

Francisco which is located at 50 Tanforan Avenue, South San Francisco, CA 94080, (650) 871 

3845 can help us and U.S. Customs and Border Protection personnel properly report and clear 

any imports subject to this exclusion once granted. 

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N232057 

September 21, 2012 

CLA-2-84:0T:RR:NC:N1:120 

CATEGORY: Classification 

TARIFF NO.: 8417.80.0000 

Mr. Matthew Williams 

Air and Surface Logistics 

1571-C Parkway Loop 

Tustin, CA 92780 

RE: The tariff classification of a Twin Pyrolysis Reactor System from China 

Dear Mr. Williams: 

In your letter dated August 23, 2012, on behalf of your client Green Envirotech, you requested a 

tariff classification ruling. 

The merchandise under consideration is a twin pyrolysis reactor system which is a functional unit 

comprised of varies machines including: an induction heat generating system, an auto load 

conveyor, induction generator electric panels and controller, pyrolysis reactors, gas/oil separator, 

distillation vessels and storage assembly, LPG gas filtration system, LPG gas compressing 

system, and storage vessels assembly, and a water tank and chiller. The twin reactors are made of 

carbon plate steel that is shaped into a cylinder and powered via 480 volts 600 KWH electricity. 

This system is not used for heat treatment but rather is designed to heat feed stock, whether it is 

used tires or used plastic, to 700 degrees Fahrenheit. At that temperature the feed stock become 

molten and starts to vaporize into a vapor that is distilled through the distillation system. 

The feed stock is placed in a reactor chamber. The system's electrical induction heating 

generator and induction coils heat the outside wall of the reactor chamber that in turn heats the 

inside diameter of the reactor where the feed stock is placed. The induction generator is 

controlled by a control panel that monitors all critical stages of the entire process. The feed stock 

becomes molten and then vaporizes. There is a separating vessel that is on the outside of the 

reactor chamber where all of the vapors pass through and are separated based on vapor weight. 

These gases are further directed to a specific distillation vessel (i.e. light oil, or vaporized LPG) 

where the vapors are distilled. The finished product, whether light sweet crude oil, or LPG gas, is 

pumped to the secondary distillation system for a secondary distillation process. 

The secondary distillation system is a reheating chamber by means of induction heating that revaporizes the distilled oil that has been fed by the pyrolysis system. The oil is pumped directly 
2 

into the reactor chamber from the pyrolysis and heated to 500 degrees Fahrenheit. This process 

further removes impurities. The vaporized oil is then passed through a separator to further 

process out the light sweet crude oil and the remaining LPG vaporized gases. The oil and gases 

are passed through a distillation process where it is liquefied into a finished product. It is then 

processed through to containment vessels where it is then moved to the final storage vessels to 

await shipment. 

The applicable subheading for the Twin Pyrolysis Reactor System will be 8417.80.0000, 

Harmonized Tariff Schedule of the United States (HTSUS), which provides for Industrial or 

laboratory furnaces and ovens, including incinerators, nonelectric, and parts thereof: Other, except 

parts. The rate of duty will be 3.9 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 Denise Faingar at (646) 733-3010. 

Sincerely, 

Thomas J. Russo 

Director 

National Commodity Specialist Division