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NY J88154




September 16, 2003

CLA-2-84:RR:NC:MM:106 J88154

CATEGORY: CLASSIFICATION

TARIFF NO.: 8419.50.5000

Mr. Mitchell Neriah
Customs Consulting Services
415 S. Prospect Ave.
Redondo Beach, CA 90277

RE: The tariff classification of an engine oil cooler from Japan

Dear Mr. Neriah:

In your letter dated August 21, 2003, on behalf of CoPAR, Inc., you requested a tariff classification ruling. You included drawings and photographs with your request.

The oil cooler under consideration consists of a plate-fin heat exchanger of stainless steel together with assorted hardware components used to assemble the heat exchanger to a Duramax diesel engine for use in various trucks. The oil cooler’s inner core (the heat exchanger) is an enclosed tubular system through which engine oil traverses in one direction while engine coolant flows through the system in the opposite direction. The heat exchanger has a plate-type core, with four stainless steel plates and two inner stainless steel fins. Engine oil flows in one direction across the fins and plates, while engine coolant runs parallel in the opposite direction. Heat from the oil is exchanged with the passing engine coolant, which itself is later cooled in the radiator assembly.

You contend that the oil cooler is an engine part classified in heading 8409, Harmonized Tariff Schedule of the United States (HTS). Parts of the machinery of chapter 84 are subject to the rules found in Section XVI, Note 2. Note 2(a) reads as follows:

[p]arts which are goods included in any of the headings of chapter 84 or 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8485, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings;

Even if the oil cooler were an integral part of the engine to which it is assembled, as you contend, it would also be described in heading 8419, which includes heat exchangers of the type at issue. Following the dictates of Section XVI, Note 2(a), cited above, the oil cooler would have to be classified in heading 8419.

The applicable subheading for the engine oil cooler will be 8419.50.5000, HTS, which provides for heat exchange units, other. The 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 Patrick Wholey at 646-733- 3013.

Sincerely,

Robert B. Swierupski
Director,

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