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March 24, 1999

CLA-2-84:RR:NC:1:110 D88399


TARIFF NO.: 8473.30.5000; 7318.19.0000; 7318.15.6060

Ms. Lisa Peterman
Micro Electronics
4119 Leap Road
Hilliard, Ohio 43026

RE: The tariff classification of a P98 CPU kit from Taiwan

Dear Ms Peterman:

In your letter dated March 3, 1999, on behalf of Micro Electronics, you requested a tariff classification ruling. Samples were submitted with the ruling request which we reviewed and used in our classification decision.

The merchandise under consideration involves a P98 CPU kit that consists essentially of one video chip heat sink, one CPU heat sink assembly and the hardware mounting kit of threaded standoffs and mounting screws. These articles will not be sold at retail as a retail kit, and thus do not meet the definition of a set as per GRI-3 (b).

The purpose of these P98 CPU kit heat sink sub-assemblies are for the final assembly and incorporation of the CPU module (Pentium II) into a P98 system which is a notebook computer. The two heat sink sub-assemblies are incorporated in a P98 system to improve the dissipation of heat generated during operation of the installed CPU. The video chip heat sink is constructed of aluminum plate with upper and lower thermal transfer tape attached. It is approximately 2 1/2 inches in length, and 2 3/4 inches in width. The CPU heat sink assembly consists of aluminum plate, a contact block, heat transfer pipe, extruded aluminum finned heat sink, and attached thermal transfer tape. It is approximately 4 1/2 inches in length, and 2 1/2 inches in width.

The assembly of these heat sinks is formed of a stack up of two heat sink plates in good thermal contact with the CPU module. The smaller heat sink goes directly over the system board mounted video chip and between the video chip and CPU plus the larger heat sink above the CPU, combine to increase the exposed surface area of these heated plates to flow of naturally connected or fan-forced flow of outside air.

As per Mr. John Buck of Micro Electronics, these heat sink assemblies are specifically designed for use with an Intel Pentium II processor type of board. Since the video IC and the Pentium II, as supplied, already have a seat sink permanently mounted on their case, but need these additional heat sinks along with a fan to increase dissipation of heat, it would appear that these two heat sink assemblies are not an integral part of the video IC or Pentium II processor. It should also be noted that the Pentium II is not a monolithic IC and is composed of several monolithic ICs and discrete components mounted on a small PCB. It is housed as a module for mounting on the mother board. It also does not meet the definition of a hybrid IC either, as per the Explanatory Notes to the HTS, since it does not use thin or thick film technology on the substrate.

The heat sink sub-assemblies before us are therefore distinguishable from those ruled on in HQ 955948. Noting Legal Note 2 (b) to Section 16 of the HTS, these specific heat sink sub-assemblies would appear to be principally used with notebook computers that incorporate a motherboard incorporating a Pentium II processor module.

The samples you furnished with this ruling request will be returned to your office.

The applicable subheading for the two heat sink sub-assemblies will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of the machines of heading 8471. The rate of duty will be free.

The applicable subheading for the internally threaded hexagon standoffs will be 7318.19.0000, HTS, which provides for other threaded articles. The rate of duty will be 5.7 percent ad valorem.

The applicable subheading for the mounting screws will be 7318.15.6060, HTS, which provides for other, other screws, having shanks or threads with a diameter of less than 6 mm. The rate of duty will be 6.2 percent 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 Art Brodbeck at 212-637-7019


Robert B. Swierupski

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