CLA-2-84:OT:RR:NC:N1:120
Mr. Jay Eizenstat
Miller Chevalier
655 Fifteenth Street, N.W., Suite 900
Washington, D.C. 20005-5701
RE: The tariff classification of liquid CPU coolers (510LC, 550LC, and 570LC) from China
Dear Mr. Eizenstat:
In your letter dated November 15, 2010, on behalf of your client Asetek, you requested a tariff classification ruling.
The merchandise under consideration includes three liquid central processing unit (CPU) coolers.
The CPU coolers, 510LC, 550LC, and 570LC are designed to be mounted directly onto an automatic data processing (ADP) machine’s motherboard making direct contact with the machine’s CPU.
The CPU coolers absorb heat from a computer’s CPU using a process called liquid cooling by which heat is removed from components in the CPU using a liquid as the heat transmitter. All of the CPU coolers incorporate a cold plate, an integrated pump, heat exchanger (radiator plus fan) and two tubes connecting the cold plate and heat exchanger. The CPU coolers operate by pumping liquid to the cold plate in which heat is absorbed by the liquid. The liquid is then pumped through a closed loop system to move the liquid to the heat exchanger where the heat is released before the liquid is pumped back to the cold plate. The basis of the liquid is water, which has a higher heat capacity.
The CPU coolers are essential to the proper functioning of the CPU of an ADP machine and are considered a part of an ADP machine of heading 8471.
The applicable subheading for the CPU Coolers (510LC, 550LC, and 570LC) will be 8473.30.5100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of heading 8469 to 8472: . . . Parts and accessories of the machines of heading 8471: Not incorporating a cathode-ray tube: . . . Other." The rate of duty will be Free.
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,
Robert B. Swierupski
Director
National Commodity Specialist Division