CLA-2-84:OT:RR:NC:N1:164
Jasmin Plehandzic
Wakefield Thermal Solutions Inc.
120 Northwest Blvd.
Nashua, NH 03063
RE: The tariff classification of finished aluminum heatsinks for plasma arc cutting machines from China
Dear Ms. Plehandzic:
In your letter dated March 25, 2025, you requested a tariff classification ruling on finished aluminum
heatsinks for plasma arc cutting machines from China. Technical information was submitted with your
request.
The items under consideration are described as finished aluminum heatsinks (eight models) for incorporation
into various Powermax plasma arc cutting machines. Specifically, each heatsink will be affixed to the printed
circuit board assembly (PCBA) in the power supply’s start circuit subassembly. During operation, the
heatsink absorbs heat generated by the PCBA and redistributes it to the side of the machine to enhance
cooling and prevent overheating. Each heatsink accomplishes this largely by the action of cooling fins which
increase surface area, improve airflow, and enhance thermal conductivity. In some cases, the subject
heatsinks also provide a mechanical dust barrier for sensitive electronic components.
The heatsinks are primarily made of extruded aluminum that undergoes additional processing to precise
specifications and tolerances. Cooling fin count, shape, and spacing are uniquely calculated based on stress
and environmental testing, including conductive and convective heat transfer analysis. Depending on the
unique heat load of each model of plasma arc cutting machine, the cooling fins vary in shape, height, and
thickness. In addition, pockets and tapped drill holes are machined on the back side of the heatsinks for
mounting and to provide proper spacing with electrical components such as capacitors and transducers.
Furthermore, the heatsinks are ground or fly cut on both sides to a precise surface finish to maintain proper
contact with the PCBA.
You state that each finished aluminum heatsink is essential for operation and can only be used with the
corresponding Powermax plasma arc cutting machine for which it was designed. In your letter, you propose
classification of the finished aluminum heatsinks in subheading 8466.93.9885, Harmonized Tariff Schedule
of the United States (HTSUS). We agree.
The applicable subheading for the finished aluminum heatsinks for plasma arc cutting machines will be
8466.93.9885, 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:
Other: For machines of headings 8456 to 8461: Other: Other: Other: Other: Other: Other. The general rate of
duty will be 4.7 percent ad valorem.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8466.93.9885, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63, in addition to
subheading 8466.93.9885, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8466.93.9885, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88. 01,
in addition to subheading 8466.93.9885, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 https://hts.usitc.gov/.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division