The tariff classification of Intercooler Kits, Oil Cooler Kits, and Transmission Cooler Kits from Japan

NY J87821 August 13, 2003 CLA-2-87:RR:NC:MM:101 J87821 CATEGORY: Classification TARIFF NO.: 8708.99.8080 Ms. Maureen Oliphant Yusen Global Logistics 19001 Harborgate Way Torrance, California 90501 RE: The tariff classification of Intercooler Kits, Oil Cooler Kits, and Transmission Cooler Kits from Japan Dear Ms. Oliphant: In your letter dated August 5, 2003 you requested a tariff classification ruling. You submitted a catalog depicting Intercooler Kits, Oil Cooler Kits, and Transmission Cooler Kits for motor vehicles. The Intercooler Kit consists of an aluminum core, aluminum pipes, silicone hoses, and metal clamps. The brochure states that the intercooler improves both the efficiency and power of any turbocharged application by rapidly reducing inherent heat levels of the compressed intake air charge before entering the engine. By utilizing a special tube and fin design, the intercooler acts as a large heat exchanger that dissipates the heat generated by the compression of the intake charge without creating reductions in boost pressure or response. As the pressurized air is channeled through the thin tubes of the intercooler core, that are filled with internal radiating fins, cool ambient air rushes through the front of the core, where the external radiating fins of the tube draw out the heat. This heat transfer decreases the likelihood of detonation by reducing the inlet temperatures and maximizes power output by increasing the density of the air inlet charge, therefore increasing overall horsepower levels as the intake charge is now cooler and denser. The Oil Cooler Kit consists of aluminum cores, steel braided lines, and metal clamps. This kit is designed to prolong the life of the engine and oil. The brochure states that factory oil coolers are normally small water-cooled devices sandwiched between the oil filter and engine block. By using a similar inner-fin core design as the Intercooler Kit, the Oil Intercooler Kit permits increased oil capacity, decreased oil temperatures, and extends engine and oil life. The Transmission Cooler Kit consists of aluminum cores, steel braided lines and clamps. The transmission cooler allows a controlled amount of ATF to bypass the stacked plate core, passing through a self-regulating orifice, which monitors resistance to flow. Controlled by viscosity, the thicker ATF is returned directly to lube through two open bypass openings in the stacked plate core. As operating temperatures increase, more of the ATF flow is directed through the core. This highly efficient cooling with optimal heat transfer results in improved protection against lube system failure. The applicable subheading for the Intercooler Kits, Oil Cooler Kits, and Transmission Cooler Kits will be 8708.99.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other…Other. The rate of duty will be 2.5% ad valorem. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Robert DeSoucey at 646-733-3008. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division