CLA-2-84:OT:RR:NC:N1:102
Mr. Wayne Bachman
Danfoss LLC
11655 Crossroads Circle
Baltimore, MD 21220-2863
RE: The tariff classification of micro-channel heat exchangers for refrigeration systems from China
Dear Mr. Bachman:
In your letter dated January 9, 2012 you requested a tariff classification ruling.
The articles in question are described as micro-channel heat exchangers for use in the refrigeration systems of refrigerated transport containers and trailers. You indicate that these particular heat exchangers are specifically designed and solely used as condensers within the refrigeration systems.
The condensers are comprised of aluminum tubes and fins. In operation, refrigerant flows into the condenser coil as a hot gas and passes through the manifold and micro-channel tubing which allows for the transfer of heat between the refrigerant and the tubing. As heat is transferred, the refrigerant condenses to its liquid state. Air moved over the outside of the coil, i.e. the tubes and fins, dissipates the heat that is transferred from the refrigerant. The fins are manufactured from rolled aluminum strips, while the aluminum micro-channel tubes used in the condenser coil are produced by standard extrusion process.
The applicable subheading for the condenser coils will be 8418.99.8060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other parts of refrigerating or freezing equipment. The rate of duty is free.
You also inquire whether this product is subject to antidumping duties or countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection. You can contact them at http://www.trade.gov/ia/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at http://www.usitc.gov (click on “Antidumping and countervailing duty investigations”), and you can search AD/CVD deposit and liquidation messages using the AD/CVD Search tool at http://addcvd.cbp.gov/.
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 Kenneth T. Brock at (646) 733-3009.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division