CLA-2-87:OT:RR:NC:N2:206

Daniel Cannistra
Crowell & Moring LLP
1001 Pennsylvania Avenue, N.W.
Washington, D.C. 20004-2595

RE: The tariff classification of engine cooling modules from Mexico.

Dear Mr. Cannistra:

In your letter dated May 1, 2020, you requested a tariff classification ruling on behalf of your client, Valeo North America Inc.

The products under consideration are Engine Cooling Modules (ECM), Part Numbers M153596 and M153595, which are used in passenger vehicles. The ECM are composed of an automatic transmission system oil cooler, engine cooling radiator, air conditioning system condenser, condenser receiver dryer, and module structural assembly frame. They are installed under the hood of the vehicle. In the event that the engine overheats, the absence of the ECM will destroy the inner mechanics of the engine. The function of the ECM is to stabilize the temperature of the engine for the vehicle to run at its most efficient state, and to keep the right temperature for the car's engine to operate at maximum potential.

The applicable subheading for the ECM, Part Numbers M153596 and M153595, will be 8708.91.5000, HTSUS, which provides for “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Radiators and parts thereof: Radiators.” The rate of duty will be 2.5% 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 https://hts.usitc.gov/current.

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, please contact National Import Specialist Liana Alvarez at [email protected].


Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division