Brian Smith
Johnson Electric North America, Inc
47660 Halyard Dr. Plymouth, MI 48170

RE: The tariff classification and country of origin of an adapter plate assembly

Dear Mr. Smith:

In your letter dated February 13, 2024, you requested a binding ruling on the tariff classification and country of origin of an aluminum adapter plate assembly.

The product under consideration has been identified as an Adapter Plate Assembly, part number 1128-1YY0121, used within the engine compartment of a battery-operated electric passenger vehicle. The adapter plate assembly connects the Integrated Thermal Management System (ITMS) to the Refrigerant Thermal Management System (RTMS), comprised of three connected chiller units within a Water-Cooled Condenser (WCC).

The Adapter Plate Assembly is intended to bridge two larger systems, the ITMS and the RTMS, indirectly acting as a mounting plate for the two systems to physically connect. It serves as a conduit for the cooling fluid by replacing a series of hoses, which reduces the complexity and number of components between this pair of complex systems.There are no control capabilities or pressure management functions within the Adapter Plate Assembly.

The Adapter Plate Assembly is comprised of three separate key elements, the Cover Casting (part number 1128 1YY0120), the Main Board Casting (part number 1128 1YY0119), and the Edge Bond Gasket (part number 1318 3JA0002), all manufactured from aluminum. They are combined using threaded fasteners (26x 1391-1JH0005 M4) and dowel pins (4x 1396-1JH0001) made of stainless steel. The Cover Casting and the Main Board Casting will be cast and formed in South Korea. The Edge Bond Gasket will be manufactured i n Mexico. The M4 Screws will be manufactured in either Mexico or Italy. The Dowel Pins will be manufactured in China. The assembly process to bring these components together will occur in Zacatecas, Mexico at the Johnson Electric manufacturing facility . Classification:

Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is, in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. The Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System, which represent the official interpretation of the tariff at the international level, facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and the GRIs.

In your submission you proposed heading 7616, HTSUS, a residual or basket provision which covers a wide range of aluminum articles that are not more specifically provided for elsewhere/in any other heading in the HTSUS. The ENs for 76.16 state that This heading covers all aluminum articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature. Since the Adapter Plate Assembly is an identifiable article of electric vehicles, it cannot be classified in heading 7676, HTSUS.

In your letter, you discussed classifying the Adapter Plate Assembly in heading 8302, HTSUS, which provides, in part, for brackets, mountings, and fittings of base metals suitable for vehicle coachwork. It appears that the Adapter Plate Assembly is not used to attach anything to a vehicle coachwork. As a result, classification in heading 8302, HTSUS, is precluded.

You also proposed the Adapter Plate Assembly may be classifiable under subheading 8419.90.3000, HTSUS, which provides for "Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Parts: Of heat exchange units." We disagree. The assembly is not a part of a heat exchange unit, but a conduit for fluid traveling between two separate systems performing different functions. Therefore heading 8419, HTSUS, would not be appropriate.

Additionally, you suggested that the Adapter Plate Assembly is classified within subheading 8481.90.9085, HTSUS, which provides for Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Other: Other: Other. In Bauerhin Techs. Ltd. P'ship. v. United States, 110 F. 3d 774 (Fed. Cir. 1997), the Court identified and defined the word part in two distinct lines of cases: first, in United States v. Willoughby Camera Stores, Inc., 21 C.C.P.A. 322, 324 (1933), a part of an article is an integral, constituent, or component part, without which the article to which it is to be joined, could not function as such article. Second, in United States v. Pompeo, 43 CCPA 9 (1955), an imported item dedicated solely for use with another article is a "part" of that article within the meaning of the HTSUS. The adapter plate assembly is not an integral, constituent, or component part of a valve or valve assembly. It is a separate and distinct item that connects the Integrated Thermal Management System to the Refrigerant Thermal Management System. As such, it is precluded from being classified as a part within heading 8481.

The applicable subheading for the Adapter Plate Assembly, part number 1128-1YY0121 will be 8708.99.8180, HTSUS, which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other: The general 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 at

Country of Origin:

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article.

The "country of origin" is defined in 19 CFR 134.1(b) as "the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the "country of origin" within the meaning of this part; however, for a good of a NAFTA or USMCA country, the marking rules set forth in part 102 of this chapter (hereinafter referred to as the part 102 Rules) will determine the country of origin."

Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile goods which are subject to the provisions of 19 C.F.R. 102.21. See 19 C.F.R. 102.11.

Applied in sequential order, 19 CFR Part 102.11(a) provides that the country of origin of a good is the country in which:

(1) The good is wholly obtained or produced;

(2) The good is produced exclusively from domestic materials; or

(3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied.

The Adapter Plate Assembly is neither "wholly obtained or produced" nor "produced exclusively from domestic materials." Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of the Adapter Plate Assembly, and paragraph (a)(3) must be applied next to determine the origin of the finished article.

The Adapter Plate Assembly is classified under subheading 8708.99, HTSUS. The tariff shift requirement in Part 102.20 for subheading 8708.99:

A change to subheading 8708.99 from any other subheading, except from parts or accessories of the goods of subheading 8708.40, 8708.50, 8708.80, 8708.91, 8708.92, 8708.94, or 8708.95.

None of the components and the materials used to produce the Adapter Plate Assembly in Mexico are classified in heading 8708, HTSUS. As a result, the applicable tariff rule shift is met. Accordingly, the country of origin of the Adapter Plate Assembly for marking purposes under 19 U.S.C. 1304 is Mexico.

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 Liana Alvarez at [email protected].


Steven A. Mack
National Commodity Specialist Division