The tariff classification of an evaporator injection tube and heater core tubes from China

N197056 January 12, 2012 CLA-2-84:OT:RR:NC:N1:102 CATEGORY: Classification TARIFF NO.: 8415.90.8045 Mr. Daniel Cannistra Crowell & Moring LLP 1001 Pennsylvania Ave. Washington, DC 20004 RE: The tariff classification of an evaporator injection tube and heater core tubes from China Dear Mr. Cannistra: In your letter dated December 13, 2011 you requested a tariff classification ruling on behalf of your client, Valeo Powertrain Thermal Systems. Descriptive literature and schematic drawings were included with your submission. The items under consideration are described by you as bent and brazed aluminum inlet tubes, part numbers T1015101Q, T1008315N and T1010031W. You indicate that these tubes are specifically designed and solely used in automobile heating, ventilation, air conditioning (HVAC) units. Based on the information submitted, part number T1015101Q is an evaporator injection tube which is used to transfer refrigerant from the evaporator to the expansion valve. The applicable subheading for the evaporator injection tube, part number T1015101Q, will be 8415.90.8045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of automotive air conditioners. The rate of duty will be 1.4 percent ad valorem. 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 on World Wide Web at http://www.usitc.gov/tata/hts/. Additional information is needed to classify part numbers T1008315N and T1010031W which are identified in your submission as heater core inlet and outlet tubes. You state that these tubes are used to transfer heat between the heater core and the engine. Do the “tubes” simply connect the heater core to the engine to allow for the transfer of engine coolant? What is the function of the tubes with respect to the vehicle’s air conditioning unit? Are the tubes essentially components that allow engine heat to be transferred to the heater core and then ultimately to the passenger compartment? When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you. 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 Kenneth T. Brock at (646) 733-3009. Sincerely, Thomas J. Russo Director National Commodity Specialist Division