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NY H82377

July 2, 2001

CLA-2-87:RR:NC:MM:101 H82377


TARIFF NO.: 8708.99.8080

Ms. Barbara Dawley
Meeks & Sheppard
Attorneys At Law
1735 Post Road, Suite 4
Fairfield, Connecticut 06430

RE: The tariff classification of an automobile radiator Water Tube from Japan

Dear Ms. Dawley:

In your letter dated June 5, 2001 you requested a tariff classification ruling on behalf of your client Denso Manufacturing Michigan, Inc.

You submitted a sample, schematic drawing and photograph of an automobile radiator Water Tube. You state that these tubes are welded, each fourteen inches in length, and are flat in appearance. You further state that these water tubes are manufactured to precise specifications for size, surface quality, wall thickness and pressure durability for direct use in automobile radiators. In their condition as imported, these water tubes will require no further processing or fabrication before being brazed to the fins and core plates located in the body of the radiator.

In your narrative you state that in operation, a radiator is designed to dissipate the heat which the coolant has absorbed from the engine. To accomplish this, radiators hold a large amount of water in tubes, such as those that are the subject of this ruling request. The water tubes, because of their flat shape, also provide a large area that is always in contact with the surrounding air. As air flows between the tubes and the fins, the heat is transferred to the air, which cools the fins, tubes and coolant. It is the precision flatness of the tubes, together with their precise wall thickness, which maximizes heat transfer between the coolant and the fin. Leakage is minimized by the welded seam, and the precision size and shape of the tube ensures proper fit with the radiator core and fins.

The applicable subheading for the automobile radiator Water Tube 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.


Robert B. Swierupski

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