CLA-2-84:RR:NC:4:102 A84377
Mr. Walter R. Manns
Ford Motor Company
West Park Center
P.O. Box 6094
Dearborn, Michigan 48121
RE: The tariff classification of fan clutch drives from either Canada or Germany
Dear Mr. Manns:
In your letter dated May 24, 1996 you requested a tariff classification ruling.
The items at issue are a series of viscous clutch fan drives imported for use with
automotive cooling fans. The units consist of two facing circular disks that rotate over each other
through complementary lands and groves. One disk turns with the engine, while the other, which
is attached to the fan, is free to spin. A thermostatic coil (except for model 712) on the front of
the drive reacts to the temperature of the air flowing over the radiator. As the coil heats up it
expands (uncoils), opening a control valve inside the clutch. This valve regulates the flow of a
viscous liquid that flows between the facing groves of the two disks. This thick fluid allows torque
to be transmitted from the engine disk to the fan disk, thereby driving the attached fan blade.
Model number 712 (Visctronic) functions somewhat differently in that it is an electronically
controlled, variable speed viscous drive. Instead of relying on direct temperature response of the
thermostatic coil, the valve is regulated by the engine management control system. The primary
function of all of these units is to engage and disengage the transfer of rotational torque from a
power source (the engine) to a driven component (fan blade).
The applicable subheading for the fan clutch drives will be 8483.60.4000, Harmonized
Tariff Schedule of the United States (HTS), which provides for clutches. The rate of duty will be
4.5 percent ad valorem. Because these clutch units are considered to be functional parts of the
automotive engine, the exclusionary language governing heading 8483 would not be applicable.
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 Karl J. Riedl at 212-466-5493.
Sincerely,
Roger J. Silvestri
Director
National Commodity Specialist Division