RE: The tariff classification of heatsink components from South Korea

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363853 August 24, 2026 CLA-2-76:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5190 Kwang Ho Lee SAMC Co., Ltd. 3rd Floor, 3 Chungjang-Daero, Jung-Gu Busan, 48939 South Korea RE: The tariff classification of heatsink components from South Korea Dear Kwang Ho Lee: In your letter dated July 30, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The merchandise under consideration is flat aluminum plates collectively described as the Grid JF2 heatsink components. The components are used in a heatsink assembly installed in a LGES JF2 Energy Storage System (ESS) battery module. There are three specific plate models in this assembly: Top A (Part # ST-JF2-TPA), Top B (Part # ST-JF2-TPB) and Bottom (Part #ST-JF2-BTM). Each plate is made of various aluminum alloys and roughly rectilinear in form. Before final assembly, each plate is imported separately in a semi-finished state. Following importation these plates are attached to each other and undergo a process creating a hermetic seal. From there they can be incorporated into the battery module, where they will circulate high-pressure coolant. In your submission, you suggest that the Top A, Top B, and Bottom are classifiable under subheading 8507.90, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Parts.” We disagree. These semi-finished components are not integral components that are directly incorporated into a battery cell, but rather intermediate shapes that need to be combined with numerous additional components to manufacture a heatsink assembly, which is subsequently used in a battery system. As they are not integral to the battery cell itself and do not contribute to the battery’s core function of storing and supplying electrical energy, they cannot be considered parts of a battery under subheading 8507.90. Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7616 state that “This heading covers all articles of aluminum other than those covered by the preceding
headings of this Chapter, or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specifically covered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616, HTSUS, if it is determined that the item is not more specifically provided for in any other heading of the tariff. The heatsink components are not specifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading 7616, HTSUS. The applicable subheading for the Top A, Top B, and Bottom (collectively the Grid JF2 heatsink components) will be 7616.99.5190, HTSUS, which provides for “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent ad valorem. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Matthew Gay at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division