Applying classification for transformer radiators

On April 12th, the General Department of Vietnam Customs (GDVC) issued dispatch No.1260/TCHQ/TXNK guiding the classification of transformer radiators.

Accordingly, transformer radiators consist of one hot oil pipe from the transformer to the radiator fins (installed at a higher position on the transformer body); one oil pipe after cooling to return to the transformer (installed at a lower position on the transformer body); corrugated fins for oil cooling are connected in parallel on two oil pipes.

Huu Nghi Customs conducts physical inspection for imported and exported goods. Photo: H.Nụ

Items used for transformers and the number and size of radiator fins depend on the capacity of the transformer (the type which has a capacity not exceeding 10,000kVA and the type which has a capacity over 10,000kVA).

The product is essentially a complete radiator consisting of many radiator fins that have been welded with oil pipes and used for transformers.

Also according to GDVC, transformer radiators are classified in heading 85.04, subheading 8504.90.

In the case that goods are transformer radiators with a capacity not more than 10,000kVA, they can be classified into the subheading "used for power transformers with a capacity not exceeding 10,000kVA", HS code 8504.90.31 "- - Radiator panels; flat tube radiator assemblies of a kind used for distribution and power transformers”.

In case the goods are transformer radiators with a capacity over 10,000kVA, they can be classified in the subheading "- - For power transformers with a capacity of over 10,000 kVA", HS code 8504.90.41 " - - - Radiator panel; flat tube radiator assemblies of a kind used for distribution and power transformers”.

GDVC said that according to the recommendation of the Technical Sub-Working Group on Classification (TSWGC) in the meeting on June 21-22, 2022, the classification of transformer radiator is appropriate with HS code 8504.90.31/8504.90.41.

The reason is that the radiator panel used for the transformer is described as a radiator for a transformer which is made up of many panels that are put together into a single unit. Each panel is made up of two embossed steel plates, welded into one to facilitate the flow of oil and increase the surface area exposed to the surrounding air. The hot oil from the transformer is fed to the plates through the top pipe and the cooled oil is brought out through the bottom pipe.

Such a type of radiator is only suitable for use in transformers with a capacity of not more than 10,000kVA or a capacity greater than 10,000kVA. Applying Rule 1 (Explanatory Notes 2(b) part 16) and Rule 6, these recommendations were made at the 11th TSWGC Meeting on June 21-22, 2022.

GDVC requested local customs departments to base on customs dossiers, technical documents, and actual imported goods and compare them with the classification instructions in Official Dispatch No. 1260/TCHQ-TXNK dated April 12, 2020 in order to classify and apply tax rates in accordance with regulations.