The tariff classification of radiator/oil cooling packages from Mexico

N246617 October 24, 2013 CLA-2-87:OT:RR:NC:N1:101 CATEGORY: Classification TARIFF NO.: 8708.91.5000 Christopher D. Hofmann, Senior HTS Classification Specialist Daimler Trucks North America 13400 West Outer Drive, Mail Stop B3A Detroit, MI 48239-1309 RE: The tariff classification of radiator/oil cooling packages from Mexico Dear Mr. Hofmann, In your letter dated September 24, 2013, you requested a tariff classification ruling. The items under consideration have been identified as engine coolant radiator/oil coolers used with Daimler motor vehicles. In your ruling request you explain that currently the merchandise is procured locally in the United States; however, there is a plan to eventually source the same items from Mexico. In your request you describe the goods in the condition of their eventual import. The first item, DTNA part number A05-29760-000, is a single article permanently assembled, comprised of the following components: (1) Radiator (1) Oil Cooler (2) Channel (1) Bracket (12) Isolator Bushings (6) Screws (8) Nuts (1) ID Label The second item, DTNA part number A05-29760-001, is also a single article permanently assembled. You state that it includes the same essential components as outlined above, but also includes the addition of four (4) M6 Speed Nuts. The channel assemblies, bracket, isolators, and fasteners are used together to facilitate the securement of the assembly in its location at the front of the vehicle. Once installed in the vehicle, the radiator and cooling package functions to keep the engine running cool by way of the following action: Coolant is drawn through the engine block and cylinder head by way of the water pump. As the coolant passes through the engine block and cylinder head, it absorbs heat from the engine. The hot coolant is then fed into the inlet tank of the radiator where it is distributed across the radiator core. As the hot coolant circulates, it transfers its heat to the internal tubes of the radiator. The tubes, in turn, transfer the heat to the fins that are attached between each row of tubes. As ram air passes over the fins, the heat is released to the ambient air. The cooled coolant is fed back to the engine, and the cycle repeats. The oil cooler portion of this radiator cooling package functions much the same as outlined above. Instead of the water pump forcing the movement of coolant through the radiator; however, it is the oil pump drawing hot engine oil through the oil cooler. It is important to note that it is still the effect of ram air which cools the engine oil, just as also occurs with the radiator and coolant. The applicable classification subheading for both radiator/cooling packages will be 8708.91.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of … motor vehicles … : Other parts and accessories: Radiators and parts thereof: Radiators: For other vehicles.” The rate of duty will be 2.5%. Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the 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 Matthew Sullivan at 646-733-3013. Sincerely, Gwenn Klein Kirschner Acting Director National Commodity Specialist Division