CLA-2-84:OT:RR:NC:N2:220
Cathy Spencer
Freight Expediters
6920 Engle Road, Suite II
Middleburg Heights, OH 44130
RE: The tariff classification of personal computer cooling components from Taiwan
Dear Ms. Spencer:
In your letter dated April 20, 2020 you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group.
The first item under consideration is identified as the TouchAqua CPU Block Summit MS, Part # BPTA-CPUMS-DRGB (TouchAqua), which is described as a water block that is used to cool the CPU processor and other electronic components inside a personal computer (PC). The TouchAqua is constructed of an acrylic block top, a back pad, paste pad, a metal back plate, a block base made of high quality C1100 copper, an RGB pin, and the springs and hardware for fastening to the CPU. In use, the TouchAqua transfers heat from the CPU to the water flowing through the block and the rest of the cooling system. The Touchaqua is equipped with digital LED RGB lighting for aesthetics.
The second item under consideration is identified as Lotan VGA Water Block, Part # BP-VG2080TIST (Lotan), which is described as a water block that is used for cooling the AUSU ROG Strix GeForce RTX 2080 and the 2080Ti graphics cards. The Lotan is constructed of an acrylic top cover, a base layer of copper that is electroplated with nickel and chromium, 0.5 mm heat dissipating fins that are positioned over the graphics processing unit (GPU), and water channels. In use, the Lotan transfers heat from the graphic card’s GPU to the water flowing through the block and the rest of the cooling system. The Lotan is equipped with digital LED RGB lighting for aesthetics.
The third item under consideration is identified as the Water Distribution Plate, Part # BP-DSWDPVYBE-MG (Distribution Plate). This article routes water or coolant to different locations via the water block, which is made of clear acrylic plastic and specifically cut to route the water from one location of the distribution plate to another allowing easier connection to other components in the cooling system. The CPU block, GPU blocks and radiators connect to the plate via plastic or acrylic tubing and metal fittings. Per your correspondence, as imported, this article does not feature any other components and is wholly acrylic plastic.
The fourth item under consideration identified as the Leviathan Radiator, Part # BP-NLXF240-F4PB (Radiator), which is made of copper tubing and fins that are brazed or welded together and brass tanks on the end of the radiator. These radiators are integrated into a water-cooled computer system to dissipate heat from the water flowing through the internal tubes and attached fins. In use, a fan would be attached to move air past the fins expelling the heat, however we would note that no fans or other components are mounted to the Radiator at the time of importation.
The fifth item under consideration is identified as the Hexagon Reservoir, Part # BP-WTH34AC-DLX-Hexagon (Reservoir), which is made from acrylic plastic. The Reservoir holds additional water or coolant and features ports allowing tubing to connect this reservoir to other components in a cooling system.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that the classification is determined first in accordance with the terms of the headings and any relative section and chapter notes.
In your request, you suggest the TouchAqua, the Lotan, and the Reservoir are correctly classified as parts and accessories for automatic data processing machines under subheading 8473.30.5100, HTSUS. With regard to the TouchAqua and the Lotan, we agree. However, the Reservoir is an add-on feature to the cooling system and not essential to the operation of the system. Thus, in our view it is not accurately described in heading 8473, HTSUS.
You also suggest that the Distribution Plate, which is imported without the integrated pump, and the Radiator, which is imported without an attached fan, are classified under subheading 8419.90.9580, HTSUS, which provides for machinery, plant or laboratory equipment, whether or not electrically heated, for the treatment of materials by a process involving a change of temperature such as heating …, other than machinery or plant of a kind used for domestic purposes …: Other machinery, plant or equipment… Other: Parts: Other: Other: Other. We disagree, as heading 8419 provides for machines, plant or equipment other than of a kind used for domestic purposes. The Distribution Plate and Radiator are used in a cooling system that is used with a personal computer. Thus, these items do not meet the terms of heading 8419.
The applicable subheading for the TouchAqua CPU Block Summit MS, Part # BPTA-CPUMS-DRGB and the Lotan VGA Water Block, Part # BP-VG2080TIST 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 headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other.” The general rate of duty will be Free.
The Water Distribution Plate, Part # BP-DSWDPVYBE-MG, and the Hexagon Reservoir, Part # BP-WTH34AC-DLX-Hexagon, would both be considered articles of plastic. As they are not provided for more specifically elsewhere, the applicable subheading will be 3926.90.9990, HTSUS, which provides for “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty will be 5.3 percent ad valorem.
In noting that the Leviathan Radiator, Part # BP-NLXF240-F4PB, is not used for industrial purposes or equipped with additional components, and therefore not more specifically provided for under heading 8419, the applicable subheading will be 7419.99.5050, HTSUS, which provides for “other articles of copper, other…other.” The general 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 the 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, contact National Import Specialist Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division