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NY J86701




July 23, 2003

CLA-2-84:RR:NC:1:110 J86701

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.5000

Ms. Cindy Sherman
UPS Supply Chain Solutions
660 Fritz Drive
Coppell, TX 75019

RE: The tariff classification of heat sink assemblies from China and Taiwan.

Dear Ms. Sherman:

In your letter dated June 3, 2003 on behalf of your client JMC Products you requested a tariff classification ruling.

The merchandise under consideration involves several heat sink assemblies. Four specific samples were submitted with your ruling request and will be returned to you. JMC Products heat sink assembly Part Numbers R1002, 1Y277, D0079 and 5U731 are similar in design with minor variations in size and shape. All four heat sink assemblies consists of an aluminum finned rectangle or round heat sink designed to be mounted directly onto an automatic data processing (ADP) machines motherboard and make direct physical contact to the machines “processor” or Central Processing Unit (CPU). Thermal interface material or grease is used between the heat sink and CPU providing efficient heat transfer. Two of the assemblies have small DC Fans with electrical connections and are attached to the heat sinks; the other two assemblies have DC Fan Blowers with electrical connections mounted onto them. Heat sink part numbers 1Y277, D0079 and 5U731 have rectangle or round finned aluminum heat sinks while part number R1002 incorporates copper heatpipes attached to a copper pad mounted to the bottom of a rectangular aluminum heat sink. These assemblies are designed to mount over the CPU and attach directly to the motherboard. The four heat sink assemblies will be imported complete with heat sinks, thermal grease, fans or fan blower’s fully assembled and ready for installation.

Today’s standard CPUs, used in currently available automatic data processing machines, generate considerable heat while operating. In response, assemblies that have become proportionately larger and more complex in design have replaced heat sinks. The function of the heat sink assembly is to absorb heat from the processor into the heat sink, which in turn is cooled by the fan. Each heat sink assembly is designed to be used with a particular CPU (e.g. Intel Pentium, Intel Pentium III, Pentium 4). The CPU itself dictates the assembly’s specific size and shape. Thermal grease, pad or tape is used between the heat sink and the CPU assuring efficient heat transfer. A heat sink assembly is essential to the proper functioning of an ADP processor. In HQ 965204, dated July 2, 2002, Customs determined that certain heat sink assemblies were part of the processing unit of an automatic data processing machine of heading 8471, Harmonized Tariff Schedule of the United States (HTS). The heat sink assemblies in question are sufficiently advanced to be neither accurately described as fans nor as a machines for the treatment of materials by cooling. Accordingly, the four heat sink assemblies are classified in subheading 8473.30.5000 HTS.

The applicable subheading for all four heat sink assemblies (Part Numbers R1002, 1Y277, D0079 and 5U731 will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessories suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other.” The general rate of duty will be free.

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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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