Guidance

Radiator for transformer (Tariff notice 16)

Check the tariff classification for a radiator for a transformer.

New regulation

A new regulation was published on 14 November 2023.

L Series

Reg. 2023/2519

This is not considered a change in Northern Ireland practice.

Classification (Combined Nomenclature (CN) code)

8504 90 17

Description of the goods

A radiator, with dimensions of approximately 520 × 700 × 3 500 mm, consisting of 2 to 32 (depending on the model) rectangular panels made of galvanised sheet metal with a grooved structure, surface welded to each other.

It is designed to be mounted on an oil-immersed power transformer, in order to cool down the transformer’s insulating oil as it flows through the radiator. By transferring excess heat into the air, the radiator prevents the transformer from overheating.

The radiator is equipped with a flanged inlet (located on the top) and a flanged outlet (located on the bottom) that are connected (using bolts and seals) to the corresponding outlet and inlet of the transformer.

The cooling may or may not be assisted by cooling fans (for faster air flow) and/or with cooling pumps (for faster circulation of the oil) according to the individual requirements.

The pumps and fans are not present at importation.

Reason

Classification is determined by general rules 1 and 6 for the interpretation of the Combined Nomenclature, Note 2(b) to Section XVI and by the wording of CN codes 8504, 8504 90 and 8504 90 17.

Classification under heading 8419 as equipment for the treatment of materials by a process involving a change of temperature is excluded, as this heading does not cover devices which involve merely an exchange of temperature with the surrounding air. The excess heat of the insulating oil flowing through the radiator simply dissipates through the walls of the radiator into the surrounding air. (See also the Harmonized System classification opinion 8431.49/2.).

Given its objective characteristics and properties, namely its construction, dimensions and position of the inlet and outlet, the radiator is suitable for use solely or principally with an electrical transformer of heading 8504, for cooling and maintaining the operating temperature of the transformer. The radiator is essential for the proper functioning of the transformer (preventing it from overheating).

The radiator is therefore to be classified under CN code 8504 90 17 as other parts of transformers and inductors.

Contact details

Tariff Classification
Customs Policy & Strategy
3rd Floor
14 Westfield Avenue
Stratford
London
E20 1HZ

Email: tariff.classification@hmrc.gov.uk

This Tariff notice is published for information purposes only.

Published 19 December 2023