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The tariff classification of a liquid-cooled busbar from China
N361444May 19, 2026CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8536.90.8585 George Tuttle, IIITuttle Law Offices3950 Civic Center Drive, Suite 102San Rafael, CA 94903RE: The tariff classification of a liquid-cooled busbar from ChinaDear Mr. Tuttle, III:In your letter dated May 11, 2026 , you requested a tariff classification ruling on behalf of your client,Amphenol Corporation.The merchandise under consideration is a liquid-cooled busbar, identified by model number LCBB-200kW.The item is further described as consisting of two longitudinal halves of electroplated copper separated by ahigh-performance thermoplastic polymer which provides electrical insulation only between the load side andthe return side of the busbar. The busbar is not externally insulated in a manner that would prevent leakage ofelectric current from the conductor or prevent it from damage. For enhanced cooling functionality, the busbarincludes two internal copper tubes which connect to the cooling system of a rack-based power system via an EPDM hose fitted with Push-Lok type fluid fittings and UQD-style stainless steel liquid quick disconnects.The busbar is enclosed in a galvanized steel cage with plastic spacers to prevent an electrical short at eachmounting location. In use, the non-insulated copper busbar functions as a passive component of a 48 VDCrack-based power system to provide a common conductive path to multiple components connected to thesame DC bus.In your request, you suggest the is classifiable under subheading 8,liquid-cooled bus bar536.90.8585Harmonized Tariff Schedule of the United States (HTSUS). We agree.The applicable subheading for the liquid-cooled busbar will be 8536.90.8585, HTSUS, which provides for"Electrical apparatus…for making connections to or in electrical circuits…for a voltage not exceeding 1,000V: Other apparatus: Other: Other." The general rate of duty will be free.The duties cited above are current as of this ruling’s issuance. 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 providedat https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS.Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.The holding set forth above applies only to the specific factual situation and merchandise description asidentified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Gary Chaffee at gary.chaffee@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division
set forth above applies only to the specific factual situation and merchandise description asidentified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Gary Chaffee at gary.chaffee@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division