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NY J86335

July 15, 2003

CLA-2-84:RR:NC:1:110 J86335


TARIFF NO.: 8473.30.5000

Mr. Kirk L. Williams
Expeditors Int’l. of Washington, Inc.
4687 World Houston Parkway, Suite 200
Houston, TX 77032

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

Dear Mr. Williams:

In your letter dated June 11, 2003 on behalf of your client Foxconn Precision Components Co., Ltd. you requested a tariff classification ruling.

The merchandise under consideration involves seven heat sink assemblies. Samples of all seven items, Part Numbers 9Y828, 322871-001, PKP118GB2D12, 2Z988-006, 22P4367, D0079 and 7Y440, were provided with your ruling request and will be retained by this office. With minor variations in size and shape, all heat sink assemblies consists of an aluminum or copper finned rectangle 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). Three of the assemblies have small DC Fans with electrical connections attached to the heat sinks; the other four assemblies have DC Fan Blowers with electrical connections mounted onto them. All seven assemblies will be imported complete with heat sinks, mounting brackets, thermal grease, pad or tape and fans or fan blower’s fully assembled and ready for installation. Part numbers PKP118GB2D12 and 7Y440 also incorporate heatpipes, and part numbers 9Y828, 322871-001, PKP118GB2D12, 2Z988-006 and 7Y440 have separate copper or aluminum bases or blocks. These assemblies are designed to mount over the CPU and attach to a retention module on the motherboard.

Today’s standard CPUs, used in currently available automatic data processing machines, generate considerable heat while operating. In response, heat sinks have been replaced by assemblies that have become proportionately larger and more complex in design. 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. Pentium 4, AMD K7, Pentium III). 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 seven heat sink assemblies are classified in subheading 8473.30.5000 HTS.

The applicable subheading for all seven heat sink assemblies (Part Numbers 9Y828, 322871-001, PKP118GB2D12, 2Z988-006, 22P4367, D0079 and 7Y440) 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.


Robert B. Swierupski

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