CLA-2-84:RR:NC:1:102 R01158
Mr. Robert J. Resetar
Porsche Cars North America
980 Hammond Drive (Suite 1000)
Atlanta, Georgia 30328
RE: The tariff classification of an engine coolant water distributor from Germany
Dear Mr. Resetar:
In your letter dated December 6, 2004 you requested a tariff classification ruling on behalf Porsche Cars North America.
The article in question is described as a “Water Distributor”. You indicate that the water distributor is a stainless steel housing that allows for the flow of coolant through a vehicle’s engine as well as to and from the vehicle’s radiators. The water distributor is attached onto the block of a spark-ignition, internal combustion engine. The vehicle’s water pump attaches directly onto the water distributor, creating the pressure necessary to move coolant through the engine cooling system. Technical drawings were submitted.
In your request you offer that the pump is properly classified in subheading 8409.91.5080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of spark-ignition, internal combustion engines. In the alternative you suggest HTSUS subheading 8708.99.8080, which provides for parts of motor vehicles.
Based on the information made available, we find that the water distributor is essentially an extension of the water pump housing. The water distributor, together with the water pump, forms a complete cooling medium pump for the engine. We find that water distributor is more specifically provided for in HTSUS heading 8413, as a part of the cooling medium pumps for internal combustion piston engines provided for in subheading 8413.30.90, HTSUS.
The applicable subheading for the water distributor will be 8413.91.9010, HTSUS, which provides for parts of pumps of subheading 8413.30.90. The rate of duty is 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 Kenneth T. Brock at 646-733-3009.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division