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 aluminum folded tubes from Mexico.
Dear Mr. Cannistra:
In your letter, dated November 9, 2021, you requested a tariff classification ruling on behalf of your client, Valeo North America Inc. Pictures and flow charts were submitted with your request.
The items under consideration are Aluminum Folded Tubes, which are used in an assembly into a radiator designed to be installed in a vehicle. The aluminum folded tubes are imported having various thickness, length, width, height, and weight. In the additional information requested by this office, you stated that prior to importation, the raw material (alloy aluminum) is folded to create an interface for a seam. Then, dimples are created on the surface, which are used to increase fluid turbulence and heat rejection capacity, and a flux agent is added to the tubes prior to exportation. At the time of exportation, the tubes are unseamed, meaning that the seam is left open when exported to the United States. The seam is only closed after importation in the final assembly process when the seam is closed via a heating process using the flux to close the seam. The folded tubes are then assembled with other subcomponents including separators, side-plates headers, tanks, and other components.
The applicable subheading for the Aluminum Folded Tubes will be 8708.91.7550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Radiators and parts thereof: Parts: For other vehicles: Other: Other.” The general rate of duty will be 2.5 percent 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