The merchandise under consideration includes three liquid central processing unit (CPU) coolers. The CPU coolers, 510LC, 550LC, and 570LC are designed to be mounted directly onto an automatic data processing (ADP) machine’s motherboard making direct contact with the machine’s CPU. The CPU coolers absorb heat from a computer’s CPU using a process called liquid cooling by which heat is removed from components in the CPU using a liquid as the heat transmitter. All of the CPU coolers incorporate a cold plate, an integrated pump, heat exchanger (radiator plus fan) and two tubes connecting the cold plate and heat exchanger. The CPU coolers operate by pumping liquid to the cold plate in which heat is absorbed by the liquid. The liquid is then pumped through a closed loop system to move the liquid to the heat exchanger where the heat is released before the liquid is pumped back to the cold plate. The basis of the liquid is water, which has a higher heat capacity. The CPU coolers are essential to the proper functioning of the CPU of an ADP machine and are considered a part of an ADP machine of heading 8471.
[1] Please importantly note that only the relevant portion of the related is displayed above. You may refer to the said customs ruling for the entire ruling explanation.
[1]. https://rulings.cbp.gov/ruling/N133281