CLA-2-76:OT:RR:NC:N5: 113
Blake Crisp
Haas Automation Inc.
2800 Sturgis Road
Oxnard, CA 93030
RE: The tariff classification of a coolant nozzle from Taiwan
Dear Mr. Crisp:
In your letter dated March 7, 2025, you requested a tariff classification ruling. Product descriptions, a
technical drawing, and photographs of the coolant nozzle were provided for our review.
The product under consideration is identified as a coolant nozzle, item number 20-5863. You described the
article as “a machined nozzle designed as a component of a computer numerically controlled (CNC) machine
tool coolant system. The nozzle is externally threaded on one side, and on the other side, the orifice from
which the coolant is sprayed measures 0.166 inches in diameter. The body of the nozzle has a hex shape for
tightly securing the nozzle to its fitting with the use of a wrench.” The coolant nozzle is machined from
aluminum alloy.
The coolant nozzle will be principally used in the United States as a component of Haas CNC machining
centers. You indicated that “When CNC machining centers are in use, the friction of the cutting tool
generates heat, which can cause damage to the workpiece and the tool itself. One solution for this is flood
coolant, in which a pump driven coolant system sprays a coolant mixture directly at the cutting tool during
operation to cool and lubricate it. The coolant also helps to disperse and dislodge chips from the
workpiece…Multiple coolant nozzles will be attached to a coolant manifold using adjustable fittings so that
the coolant can be manually positioned to spray directly onto tools of varying lengths. This coolant manifold
is then assembled into the spindle head of the machine.” The entire coolant sub-system includes nozzles,
fittings, filters, a manifold, and a pump, all of which are integrated throughout the machine tool and
connected by tubes and hoses. The coolant flow is controlled by the CNC control unit.
In your letter, you propose that the coolant nozzle is classified in heading 8466, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for Parts and accessories suitable for use solely or principally
with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing
heads and other special attachments for the machines; tool holders for any type of tool for working in the
hand. We disagree.
Merchandise imported into the United States is classified under the HTSUS. Tariff classification is governed
by the principles set forth in the General Rules of Interpretation (“GRIs”) and, in the absence of special
language or context which requires otherwise, by the Additional U.S. Rules of Interpretation. The GRIs and
the Additional U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory
provisions of law for all classification purposes.
GRI 1 requires that classification be determined first according to the terms of the headings of the tariff
schedule and any relative section or chapter notes. If the goods cannot be classified solely on the basis of GRI
1, and if the heading and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be
applied in order.
As noted in H310746 (February 3, 2021), the term “part” is not defined in the HTSUS. In the absence of a
statutory definition, the courts have fashioned two distinct but reconcilable tests for determining whether a
particular item qualifies as a part for tariff classification purposes. See Bauerhin Technologies Limited
Partnership, & John V. Carr & Son, Inc. v. United States, 110 F.3d 774 (Fed. Cir. 1997). Under the first test,
articulated in United States v. Willoughby Camera Stores, 21 C.C.P.A. 322 (1933), an imported item qualifies
as a part only if it can be described as an “integral, constituent, or component part, without which the article
to which it is to be joined, could not function as such article.” Bauerhin, 110 F.3d at 779.
Pursuant to the second test, set forth in United States v. Pompeo, 43 C.C.P.A. 9 (1955), a good is a “part” if it
is “dedicated solely for use” with a particular article and, “when applied to that use…meets the Willoughby
test.” Bauerhin, 110 F.3d at 779 (citing Pompeo, 43 C.C.P.A. at 14); Ludvig Svensson, Inc. v. United States,
63 F. Supp. 2d 1171, 1178 (Ct. Int'l Trade 1999) (holding that a purported part must satisfy both the
Willoughby and Pompeo tests). An item is not a part if it is “a separate and distinct commercial entity.”
Bauerhin, 110 F.3d at.779.
In the instant case, the coolant nozzle facilitates and directs the spray of coolant fluid as desired during
operation. You stated that the inside diameter and length is designed to allow an optimal spray pattern which
consequently affects the performance of a coolant subsystem. However, beyond the basic physical
dimensions, the item does not feature specialized physical characteristics, adjustability, or mechanical
components which provide unique and indispensable capabilities required for coolant subsystem functioning.
Furthermore, the coolant nozzle attaches to other coolant subsystem components by common 1/8” National
Pipe Thread (NPT) threading on the external articulating surface. In correspondence, you stated that the
nozzles are interchangeable with many machining centers as well as any 1/8” NPT fitting, evidencing that
this aspect of the coolant nozzle is nonspecific, unspecialized and suitable for use in a variety of applications.
Lastly, the body of the coolant nozzle features a hex-shaped protrusion for tightly securing the nozzle to its
fitting with the use of a wrench. This feature is also common and does not require a specialized tool or other
apparatus dedicated for use with the machining center coolant subsystem. Accordingly, classification in
heading 8466, HTSUS, is precluded.
Heading 7616, HTSUS, is 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 Explanatory Notes
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.” An article of
aluminum would only be classified in heading 7616 if it was determined that the item is not more specifically
provided for in any other heading of the tariff. Noting that the coolant nozzle is not more specifically
provided for in heading 8466, HTSUS, or in any other heading of the tariff, the articles under consideration
will be classified under heading 7616, HTSUS, which provides for Other articles of aluminum because the
nozzle is not more specifically provided for elsewhere/in any other heading in the HTSUS.
The applicable subheading for the coolant nozzle, item number 20-5863, will be 7616.99.5190, HTSUS,
which provides for Other articles of aluminum: Other?Other. The rate of duty will be 2.5 percent ad
valorem.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 25 percent are reflected in
Chapter 99, headings 9903.85.04 and 9903.85.07.?Products provided by heading 9903.85.08 will be subject
to a duty of 25 percent upon the value of the aluminum content.?At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.85.07, in addition to subheading
7616.99.5190, HTSUS.?Derivative aluminum articles processed in another country from aluminum articles
that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the
additional ad valorem duties.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division