CLA-2-87:OT:RR:NC:N1:101

Dwight J. Voakes, International Logistics Manager
Cooper Standard Automotive, Inc.
39550 Orchard Hill Place
Novi, MI 48375-5329

RE: The tariff classification of cooling tubes from England

Dear Mr. Voakes,

In your letter dated January 14, 2010, you requested a tariff classification ruling.

The items under consideration are three (3) models of finned Cooling Tubes that are used in the construction of the power steering system of Nissan light trucks. You state that all three Tubes are imported in a straight condition and are bent during their final processing.

The first item, Part number 1018901:

The second item, Part number 1018902:

The third item, Part number 1018639:

The fins of the Tubes, which are covered by a protective cardboard sleeve in the pictures of models 1018902 and 1018639, allow some of the heat from power steering fluid to dissipate by a) allowing heat to escape from the tube and b) the fins, themselves, being cooled by ambient air.

The applicable classification subheading for the three (3) models of Cooling Tubes (Parts # 1018907, 1018902 and 1018639) will be 8708.91.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts … of … motor vehicles … : Other parts…: Radiators … : 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://ww.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 Richard Laman at 646-733-3017.


Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division