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NY F87838





June 7, 2000

CLA-2-87:RR:NC:MM:101 F87838

CATEGORY: CLASSIFICATION

TARIFF NO.: 8708.99.8080

Ms. Brenda K. Osborne
Manager, Customs Compliance
Mitsubishi Motor Sales of America, Inc.
6400 Katella Avenue
Cypress, California 90630-5208

RE: The tariff classification of a motor vehicle Engine Oil Cooler and Transmission Oil Cooler from Japan

Dear Ms. Osborne:

In your letter dated May 31, 2000 you requested a tariff classification ruling.

You submitted diagrams of the automotive parts.

Part Number: MB605467 Engine Oil Cooler (part name code 43000). The function of the oil cooler is to lower the temperature of the engine lubricating oil. Hot oil is transported to the oil cooler through a steel pipe. While in the oil cooler, oil travels through a series of finned tubes, which provide space for the passage of air (similar to a radiator). The passage of air around the oil cooler tubes creates a heat exchange process in which heat is removed from the oil out to the environment. After the heat exchange process, cooled oil is returned to the engine via an oil return line. The oil cooler does not incorporate pressure switches, temperature sensors or any other electrical components.

Part Number: MD755020 Transmission Oil Cooler (part name code 25800). The function of this part is similar to the Engine Oil Cooler except that it cools transmission fluids. The transmission fluid is fed through a line directly into a series of tubes (similar to a radiator) where the fluid is then cooled via the passage of air. The transmission oil cooler does not incorporate pressure switches, temperature sensors or any other electrical components.

The applicable subheading for the Engine Oil Cooler and Transmission Oil Cooler 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: OtherOther. 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 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,

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