CLA-2-84:OT:RR:NC:1:120

Mr. Timo Minx
Cool IT Systems, Incorporated
3920 29th Street NE
Calgary, Alberta T1Y6B6
Canada

RE: The tariff classification of a CPU heat sink assembly from China

Dear Mr. Minx:

In your letter dated April 21, 2010 you requested a tariff classification ruling.

The merchandise under consideration is a heat sink assembly specifically designed via shape and size to absorb heat from the AMD, AM2, A M2+ and AM3, as well as Intel LGA775, LGA1156 and LGA1366 processors. The heat sink assembly comprises an aluminum radiator, cooling fan, pump, and copper coldplate. It is screwed onto the computer’s motherboard over the central processing unit (CPU) chip. In operation, heat is absorbed from the processor through a copper metal plate (coldplate) into the sealed liquid loop, and moved via a small pump to the radiator where heat is rejected to ambient air with the use of a fan. The radiator features fins to increase surface area to remove more heat energy.

The heat sink is essential to the proper functioning of the CPU of an automatic data processing (ADP) machine and is considered a part of an ADP machine of heading 8471.

The applicable subheading for the heat sink assembly 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