Classification of Aluminium Layered Oil Coolers as Heat Exchange Units under Heading 8419.50.92

Background of the Advance Ruling

M/s. Modine Thermal Systems Private Limited approached the Customs Authority for Advance Rulings, Mumbai (CAAR Mumbai) seeking clarity on the customs classification of Aluminium Layered Oil Coolers proposed to be imported into India. The application was filed under Section 28H(2)(a) of the Customs Act 1962, which allows an assessee to seek an advance ruling on the determination of the classification of goods.

The core dispute revolved around whether these oil coolers should be:

  • Classified under Heading 8419, specifically 8419.50.92, as “Heat Exchange Units – Plate Type”, or
  • Treated as “Parts and accessories of the motor vehicles of Headings 87.01 to 87.05” under Heading 8708.

The difference in classification had direct implications on the applicable Basic Customs Duty (BCD), with 8419.50.92 attracting 7.5% and 8708 attracting 15%.

Product Overview – Aluminium Layered Oil Coolers

Construction and Working Principle

The product in issue is a plate-type heat exchanger constructed from multiple thin aluminium plates that are brazed together to form a compact block with alternating flow channels. The key features include:

  • Corrugated or patterned aluminium plates stacked to create separate channels
  • Engine oil flowing through one set of channels
  • Coolant flowing through adjacent channels, typically in counter-flow
  • Heat transfer occurring through thin metal walls due to temperature differential
  • No mixing of oil and coolant because of sealed and brazed construction

The brazing ensures leak-proof internal sealing between alternate layers, while gaskets/seals used during engine assembly prevent external leakage when the unit is mounted on the engine.

Functional Role in the Engine System

The Authority recorded that the oil cooler performs the following essential functions:

  1. Temperature Control
    It keeps engine oil within a defined operating temperature band by removing excess heat and transferring it to the coolant.

  2. Preservation of Lubricating Properties
    By preventing overheating, the device helps to maintain the oil’s viscosity and lubricating characteristics, ensuring proper protection of moving engine parts.

  3. Avoidance of Thermal Degradation
    The system reduces the risk of chemical breakdown and oxidation of oil caused by prolonged exposure to high temperatures.

  4. Improvement in Engine Performance and Life
    Consistent oil temperature translates into lower wear and tear, enhanced engine efficiency and an extended operational life of critical components.

  5. Mechanical and Thermal Durability
    The brazed aluminium construction is engineered to withstand high temperatures, pressure pulsations, and vibrations typical of engine environments, while remaining lightweight.

Material and Design Highlights

  • Manufactured using high-grade aluminium alloys for:
    • High thermal conductivity
    • Adequate mechanical strength
    • Corrosion resistance
  • Key elements include:
    • Precision-formed plates with brazed joints
    • Protective coatings against corrosion (as applicable)
    • Sealing materials compatible with engine oil and coolant

Application and Location of Use

The oil coolers are intended for use in internal combustion engines fitted in:

  • Passenger cars
  • Commercial vehicles
  • Heavy-duty construction equipment
  • Agricultural machinery

They are installed in the lubrication circuit, typically in the path between the oil pump and the engine components requiring controlled-temperature lubrication.