Imported 'Heat Sink' Is Within Aluminum Extrusion Orders, Scope Ruling Says

A heat sink manifold imported by Wagner Spray Tech Corporation is subject to the antidumping and countervailing duty orders on aluminum extrusions from China, despite an exemption from those orders for heat sinks, the Commerce Department said in an Oct. 17 scope ruling.

Wagner described the product at issue as a “heat sink manifold,” which Wagner states is a component part to its Titan 440 paint sprayer. The part allegedly absorbs heat created by a paint sprayer’s pump and electronic equipment and controls the flow and pressure of paint through the sprayer. The part is attached to the bottom of the paint sprayer device and is exposed to the air to allow for effective heat dissipation. Wagner said that the part consists of extruded aluminum 6061-T6 alloy "because of its heat dissipating qualities."

Wagner filed the request in November 2022 and argued that the part was outside the scope of the orders due to the “finished heat sink” exclusion.

Commerce disagreed, noting that the owner’s manual for the Titan 440-series referred to the part as a “pump block” which houses other components of the sprayer. Combined with Wagner’s own description of the part as controlling the flow of paint, that suggests that the primary purpose is not that of a heat sink, Commerce said.

Commerce noted that the criteria for meeting the exception required that specific thermal performance requirements must exist and that the product must have been designed around meeting those requirements. The department found that "while Wagner has demonstrated that standards for safe operating temperatures exist for the downstream product," it found that Wagner didn't show that specified thermal performance requirements existed for the particular part at issue.