CLA-2-87:OT:RR:NC:N2:206
Hayley Turner
Pro Alloy Motorsport Ltd.
15 Rookwood Way
Haverhill CB9 8PB
United Kingdom
RE: The tariff classification of a radiator, intercooler, header tank, boost pipes, and a fuel tank from the
United Kingdom
Dear Ms. Turner:
In your letter dated March 5, 2026, you requested a tariff classification ruling.
The subject merchandise is a radiator, intercooler, header tank, boost pipes, and a fuel tank, which are used
with passenger vehicles.
The first item is a Lotus Radiator (Part Number ELISERAD1PS), which is mounted in the front of the
vehicle. It is made of 100 percent aluminum. You state that when fuel burns inside the engine cylinders, it
creates extreme heat (up to ~2,000°C during combustion). While only some of that heat becomes useful
power, a large portion must be removed to prevent engine damage. The coolant circulates through passages
in the engine block and cylinder head and absorbs the heat. As it heats up, it flows to the radiator. The metal
fins transfer that heat to surrounding air. Airflow (from driving or the cooling fan) carries heat away .
The second item is a Fiesta MK7 Intercooler (Part number INTFFIEMK7CURVS), which is a heat exchanger
designed to cool the compressed, high-temperature air produced by a turbocharger or supercharger before it
enters the engine. When this air is cooled, its density increases, allowing more oxygen to enter the
combustion chamber. This enables the engine to burn fuel more efficiently, resulting in increased power
output, improved throttle response, and enhanced combustion reliability. It is made of 100 percent aluminum
for optimal heat dissipation, durability, and lightweight performance.
The third item is a Header Tank/Expansion Tank (Part number LotusS2HTPB), which is a part of the cooling
system. As the coolant circulates through the engine block, it absorbs heat and expands. This increase in
volume is directed into the expansion (header) tank, preventing excessive pressure build-up within the
cooling system. The tank is typically mounted at the highest point in the system so that any trapped air
bubbles naturally rise into it and are expelled through the overflow. This helps prevent airlocks, ensuring
consistent coolant flow and stable engine temperatures. When the engine is switched off and begins to cool,
the coolant contracts. The resulting vacuum draws the excess coolant from the expansion tank back into the
radiator and engine block, maintaining the correct fluid level throughout the system. The tank is made of
95% aluminum for enhanced strength and durability.
The fourth item is a Boost Pipes Kit (Part Number PKFFIEMK7S-1), which is a boost pipework that ensures
consistent airflow between the turbocharger, intercooler, and intake manifold. By maintaining smooth,
uninterrupted airflow under boost, it helps reduce turbo lag and prevents air leaks that can starve the engine
and turbo of vital air supply. The pipes are manufactured with a slightly larger internal diameter than original
equipment manufacturer (OEM) plastic or rubber equivalents, allowing improved airflow. With precision
mandrel-bent curves, airflow remains smooth and unrestricted, promoting quicker throttle response and more
efficient engine performance. The pipework is manufactured from 100% aluminum and supplied with
high-quality silicone joiners and aluminum hose clamps for secure installation.
The fifth item is a Fuel Tank (Part number FTLOTUSS148), which is a sealed fuel storage system, designed
to safely store petrol (gas) or diesel and efficiently deliver it to the engine while effectively managing fuel
vapors. When the fuel enters the tank through the filler neck it passes internal baffles that help prevent
overfilling. These internal walls are specifically designed to reduce fuel movement during acceleration,
braking, and cornering, which improves vehicle stability by limiting fuel slosh, maintaining consistent fuel
pickup, and transferring fuel through the fuel lines to the combustion engine. The fuel tank is made from 98%
aluminum, providing strength, durability, and corrosion resistance.
The applicable subheading for the Lotus Radiator (Part Number ELISERAD1PS) and Fiesta MK7 Intercooler
(Part number INTFFIEMK7CURVS) will be 8708.91.5000, 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: Radiators and parts thereof: Radiators: For other vehicles.” The general rate of duty
will be 2.5 percent ad valorem.
The applicable subheading for the Header Tank/Expansion Tank (Part number LotusS2HTPB), Boost Pipes
Kit (Part Number PKFFIEMK7S-1), and Fuel Tank (Part number FTLOTUSS148) will be 8708.99.8180,
HTSUS, which provides for “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other
parts and accessories: Other: Other: Other: Other: Other: Other”. The general rate of duty will be 2.5 percent,
ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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