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NY F87761

June 16, 2000

CLA-2-84:RR:NC:MM:110 F87761


TARIFF NO.: 8473.30.5000

Mr. Mitchell Neriah
415 So. Prospect Ave. Ste. 110
Redondo Beach, CA 90277

RE: The tariff classification of part number 47M202599GPROTO "HEAT SINK ASSY" and part number 47P200644PROTO "HEAT SINK HOLDER" from Japan.

Dear Mr. Neriah:

In your letter dated May 23, 2000, on behalf of Toshiba America Information Systems, Inc. (TAIS) you requested a tariff classification ruling.

The merchandise in question consists of two items. The first item is part number 47M202599GPROTO "HEAT SINK ASSY", which is an aluminum heat sink. It is an irregularly shaped aluminum article with small posts on one side, which act as heat radiator fins to remove heat. The heat sink has three small EMI gaskets (electro-magnetic interference shields made of metalized yarn wrapped around polyurethane foam) permanently attached by adhesive. There is a square rubber thermal pad on the "HEAT SINK ASSY" which has the exact dimensions of the CPU chip. The "HEAT SINK ASSY" is mounted over the CPU chip on the motherboard along with a cooling fan to remove heat from the CPU. The "HEAT SINK ASSY" is placed directly upon the CPU chip, the rubber thermal pad makes direct physical contact with the CPU. The "HEAT SINK ASSY" is not designed as part of the CPU, but is designed to absorb heat from the CPU only. The second item, part number 47P200644PROTO "HEAT SINK HOLDER" is a copper alloy (brass) support upon which the heat sink assembly is mounted. The "HEAT SINK HOLDER" is placed over the top of the "HEAT SINK ASSY" and is attached to the notebook cabinet.

The applicable subheading for both the "HEAT SINK ASSY" and "HEAT SINK HOLDER" will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Parts and accessories (other than covers, carrying cases and the like) 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 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 212-637-7019.


Robert B. Swierupski

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