CLA-2-84:RR:NC:N1:106 M82308

Mr. Chris Lundy
UTI/DFW
801 Hanover Ste. 100
Grapevine, TX 76051

RE: The tariff classification of a CPU Cooler and USB Beverage Chiller from China.

Dear Mr. Lundy:

In your letter dated May 8, 2006, on behalf of CoolIT Systems, Inc., you requested a tariff classification ruling. You submitted a description with your request.

The first article in question is the Freezone CPU Cooler, UPC number 857073001010. This is a commercial product designed to cool commercial computers. You indicate that the Freezone CPU Cooler is a liquid cooling system that is primarily installed into desktop personal computers. The product uses a Fluid Heat Exchanger (FHE) that is placed on the computer’s Central Processor Unit (CPU). In operation, the heat from the CPU is transferred to the FHE, which then transfers the heat to a circulating fluid. The fluid is then pumped to the FHEs positioned on a heat sink, where the heat is transferred from the fluid to the heat sink and exhausted out of the computer via a fan. A 12V DC that is supplied by the computer’s internal power supply powers the liquid cooling system.

The USB Beverage Chiller, UPC number 857073001997, is a commercial product designed to cool canned beverages. The USB Chiller is a beverage cooler that is powered by a USB port on a laptop or desktop computer. The chiller uses a cold plate that the beverage (soda can, for example) is placed on. In operation, heat is transferred via a Thermal Electric Cooler (TEC) that is sandwiched between the cold plate and a heat sink. The heat is exhausted from the heat sink and unit via a fan. A 5V DC that is supplied by the computer’s USB port powers the chiller.

The applicable subheading for the Freezone CPU Cooler will be 8419.89.9540, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other machinery, plant or laboratory equipment, whether or not electrically heated, for the treatment of materials by a process involving a change of temperature: designed for cooling: other. The rate of duty will be 4.2 percent ad valorem.

The applicable subheading for the USB Beverage Chiller will be 8419.89.9520, HTSUS, which provides for other machinery, plant or laboratory equipment, whether or not electrically heated, for the treatment of materials involving a change of temperature: designed for cooling: for food and beverages. The rate of duty will be 4.2 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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,
National Commodity
Specialist Division