CLA-2-84:OT:RR:NC:N1:102
Jiwon Kwon
Cusan Customs Service Incorporation
#309, 35, Magokjungang 2-ro, Gangseo-gu
Seoul 07806
South Korea
RE: The tariff classification of a coolant hub module from South Korea
Dear Jiwon Kwon:
In your letter dated July 29, 2025, you requested a tariff classification ruling on behalf of your client,
Myunghwa Industry Co. Ltd. Descriptive information was submitted for review.
The product at issue is a coolant hub module, item number 25429-CV500, which is referred to as a vehicle
coolant reservoir. The module, which is part of a cooling system used in an electric vehicle, is a composite
good that consists of two single suction water pumps, a reservoir with a 2.2. liter capacity, a three-way valve,
and various hoses and mounting brackets. In use, the closed coupled pumps discharge coolant stored in the
reservoir out of 1.89-centimeter outlets to dissipate heat released by the battery system and various electrical
systems.
In your letter, you suggest the module is classified within subheading 8708.99.8180, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Parts and accessories of the motor vehicles of
headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other. We disagree.
While the module is used in an electrical vehicle, it is not an integral component part of the vehicle. It is an
integral component part of a cooling system that is used to cool components in a vehicle, and therefore, the
module is excluded from heading 8708.
Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with
General Rule of Interpretation (GRI) 3, HTSUS. GRI 3(a) states in part, when two or more headings each
refer to part only of the materials or substances contained in mixed or composite goods, those headings are to
be regarded as equally specific, even if one heading gives a more precise description of the good. Goods
classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them
their essential character, which may be determined by the nature of the material or component, its bulk,
quantity, weight or value, or by the role of a constituent material in relation to the use of the article. In this
case, the pumps impart the essential character of the module, as they release coolant that lowers the
temperature of various systems. Pumps that transfer fluid are provided for within heading 8413.
Accordingly, the applicable subheading for the coolant hub module will be 8413.70.2005, HTSUS, which
provides for Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof:
Other centrifugal pumps: Other: Other: Single-stage, single-suction, close-coupled: With discharge outlet
under 5.08 cm in diameter. The general rate of duty will be Free.
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. At this time, products of South Korea
will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e., 9903.02.56, in addition to subheading
8413.70.2005, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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
(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 Sandra Martinez at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division