OT:RR:NC:N2:206
Steven Zisser
Zisser Customs Law Group, PC
9355 Airway Road, Suite 1
San Diego, CA 92154
RE: The country of origin of an aluminum radiator
Dear Mr. Zisser:
In your letter dated February 17, 2026, you requested a country of origin ruling on an aluminum radiator,
which you filed on behalf of LT Automotive Parts Company Limited.
The article under consideration is an aluminum radiator (Part Number 2370), which is used in passenger
vehicles. The radiator’s main purpose is to keep an engine at the optimal operating temperature, which it
achieves by absorbing excess heat generated by the engine and lowering the coolant temperature with the air
passing through the vehicle’s front grille. The aluminum radiator delivers cooling efficiency due to its high
thermal conductivity and its ability to absorb heat much more quickly than other materials. The aluminum
radiator is comprised of essentially two main parts: an aluminum core, which is the main section of a
radiator, and inlet/outlet tanks, where the hot coolant begins its flow into the core for cooling.
According to the bill of materials provided with your request, the aluminum rolls and aluminum sheets for
the core, inlet/outlet tanks, and other components, such as header and side plates, an oil cooler, fittings,
gasket, grommets, steel rings, etc. and are made in China and imported to Vietnam for further processing and
assembly.
The aluminum rolls are cut and rolled into flat tube profiles of the required width in Vietnam. The rolled
tubes are high frequency brazed along the seam to create a sealed hollow tube. The completed aluminum
tubes are cut to length and inspected for dimensional accuracy. The aluminum sheets are fed into a
roll-forming machine to create the desired fin geometry. Formed fins are cut to precise dimensions and
stacked for core assembly. Each batch undergoes quality control checks for uniform thickness, shape, and
spacing specifically for use in the radiator core assembly.
The tubes and fins are then stacked and aligned with the header and side plates to form the radiator core. The
assembled core passes through a continuous nitrogen-protected brazing furnace, which melts the brazing flux
and bonds all aluminum parts into a single solid core. The brazed core cools and is inspected for leaks,
alignment, and structural integrity. The inlet and outlet tanks and gaskets are mechanically attached to the
core, forming the complete radiator unit.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
CBP previously ruled on a similar scenario in ruling N338204, dated March 1, 2024. In that ruling, we stated,
“[a]s we have already established, the main components of the radiator are the aluminum core and the
up/bottom tanks. Although the processes in Mexico may appear to not be overly complex, the raw aluminum
from China is nonetheless substantially transformed into identifiable components of a radiator in Mexico. As
a result, we have a Mexican radiator core and Chinese up/bottom tanks. Since the final assembly of all
components into a complete aluminum radiator occurs in Mexico, it is the opinion of this office that the
country of origin of the aluminum radiator will be Mexico…”
Similarly in this case, the Chinese aluminum rolls and sheets are substantially transformed in Vietnam into
tubes and fins, which are eventually assembled into the core. The final assembly of all components also
occurs in Vietnam. Therefore, the country of origin of the aluminum radiator (Part Number 2370) will be
Vietnam.
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 Liana Alvarez at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division