C l a s s i f i c a t i o n ; C o u n t r y o f O r i g i n

N338985 April 11, 2024 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification; Country of Origin TARIFF NO.: 9031.49.9000 Nathan Besh Besh Consulting Pty Ltd, Trading as NateChrony 7 Broughton Place Davidson 2085 Australia RE:  The tariff classification and country of origin of a ballistic chronograph Dear Mr. Besh: In your letter dated March 19, 2024, you requested a tariff classification, country of origin, marking, and United States-Australia Free Trade Agreement determination ruling. Descriptive literature was provided for our review. The item under consideration is described as the NateChrony, which is a ballistic chronograph that is attached to the barrel of an air rifle (non-powder burning devices) to measure the velocity of the projectile. The chronograph is either screwed on, if the barrel is threaded, or clamped on, if it is an unthreaded barrel. The device is powered via a USB cable from a separately imported USB power bank or portable device. The data collected from the NateChrony is used to measure pellet speed as well as calculate trajectory information, and is displayed via website on a connected device. Additional information includes minimum speed and power, maximum speed and power, average speed and power, spread of speed and power, and standard deviation of speed and power. The device provides measurements in both metric and imperial units including feet per second (meters per second), foot pounds (joules), and grains (grams). The chronograph contains two infrared photologic sensors at each end of the device that include multiple electronic components packed into the single integrated sensor. The sensor has a photodiode with additional processing circuits to enable it to act as an electrical switch that is triggered by infrared. In operation, the pellet passes through the first sensor, which will detect the pellet, and measures the time it takes to get to the second sensor before providing the calculations.    The applicable subheading for the NateChrony ballistic chronograph will be 9031.49.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other optical instruments and appliances: Other: Other.” The general rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. Regarding the United States-Australia Free Trade Agreement (UAFTA) eligibility, General Note (GN) 28(b), HTSUS, sets forth the criteria for determining whether a good is originating under the UAFTA. GN 28(b), HTSUS, states in pertinent part that: For the purposes of this note, subject to the provisions of subdivisions (c), (d), (m) and (n) thereof, a good imported into the customs territory of the United States is eligible for treatment as an originating good of a UAFTA country under the terms of this note only if: (i) the good is a good wholly obtained or produced entirely in the territory of Australia or of the United States, or both; (ii) the good was produced entirely in the territory of Australia or of the United States, or both, and- (A) each of the non-originating materials used in the production of the good undergoes an applicable change in tariff classification specified in subdivision (n) of this note; (B) the good otherwise satisfies any applicable regional value content requirement referred to in subdivision (n) of this note; or (C) the good meets any other requirements specified in subdivision (n) of this note; and such good satisfies all other applicable requirements of this note; (iii) the good was produced entirely in the territory of Australia or of the United States, or both, exclusively from materials described in subdivision (b)(i) or (b)(ii) of this note; or (iv) the good otherwise qualifies as an originating good under this note. In addition, GN 28(c)(iii), HTSUS states that: A good that has undergone production necessary to qualify as an originating good under this note shall not be considered to be an originating good if, subsequent to that production, the good undergoes further production or any other operation outside the territory of Australia or of the United States, other than unloading, reloading or any other operation necessary to preserve the good in good condition or to transport the good to the territory of Australia or of the United States. As the good contains non-originating materials, it would have to undergo an applicable change in tariff classification in order to meet the requirements of GN 28(b)(ii). We must refer to GN 28(n) for the specific classification changes required. For goods classified in subheading 9031.49.9000, GN 28(n)/64(A) requires: A change to subheadings 9031.10 through 9031.80 from any other heading. The microprocessor board, circuit board, 3D printer filament and connectors are produced in China. The sensors, screws and resistors are sourced from various countries. In Australia, the various components are soldered to the circuit board, the 3D printed components are manufactured, the chronograph is assembled (screwed into place), the essential proprietary software is created and loaded, the protective coatings are added to the circuit board and all final testing is performed. It is our opinion that all of the non-originating material undergoes the required tariff shifts. Based on the facts provided, the NateChrony ballistic chronograph is eligible for UAFTA preferential treatment, because it meets the requirements of GN 28(b)(ii). Regarding the country of origin, the marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. The “country of origin” is defined in 19 CFR 134.1(b) as “the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the 'country of origin' within the meaning of this part.” The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character or use, different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 69 C.C.P.A. 151 (1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In determining whether the combining of parts or materials constitute a substantial transformation, the issue is the extent of operations performed and whether the parts lose their identity and become an integral part of a new article. In this instance, the microprocessor board and circuit board are generic boards that have many different uses. The additional soldering of components to the board, the addition of the sensors (allowing for the measurement to occur), the construction and adding of the 3D printed components, and the adding of the proprietary software are all essential items to transform the articles into a working chronograph. Therefore, it is our opinion that the country of origin of the NateChrony ballistic chronograph will be Australia. Regarding the marking, in your letter, you indicate your intentions to solely utilize the “Australian made logo” on your packaging. The logo consists of a green triangle with a kangaroo design within the triangle. It is our opinion that the logo alone would not be enough to clearly indicate the country of origin of the chronograph to the end consumers. In lieu of the logo, or in addition to, we suggest utilizing the terms “made in Australia” on your product. This marking will conform to all U.S. importing laws and clearly identifies the country of origin to the end consumer. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division


C o u n t r y o f O r i g i n , T r a d e A g r e e m e n t , C l a s s i f i c a t i o n

N342274 September 24, 2024 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Country of Origin, Trade Agreement, Classification TARIFF NO.: 8541.43.0010, 9903.88.02 Chris Tovar Consulting by Sandra Tovar, Inc., DBA CST Inc. 500 Westpark Dr. Peachtree City, GA 30269 RE: The tariff classification, country of origin and status under the United States-Australia Free Trade Agreement (UAFTA) of solar panels from Australia. Dear Mr. Tovar: In your letter dated August 26, 2024, you requested a ruling on the classification, origin and status of solar panels from Australia under the UAFTA, on behalf of your client, Tindo Operations Co Pty Ltd. The items concerned are solar panels, part numbers Walara-425-54G3P, Walara-430-54G3P, Walara-570-72G3P, Walara-575-72G3P. The solar panels are made from mono crystalline solar cells manufactured within China and various other components of various countries of origin. The components are imported into Australia by Tindo Operations Co Pty Ltd. for further manufacturing and assembly into the final solar panel. The modules in question are primarily designed for connection in strings to grid-tie inverters or to microinverters for residential or small commercial applications. The manufacturing steps undertaken within Australia include the following: Cell Cutting Stringing the Cells Glass, Front Encapsulant and Layup Busbar Soldering QA Checks and Bar Coding Cell Taping, Back POE, Backsheet Layup EL Testing Lamination Edge Trimming Visual inspection and cleaning Framing Junction Box Soldering Junction Box Potting and Curing Junction Box finishing, flash testing and Pelletizing A complete explanation of the manufacturing steps undertaken in Australia was provided with the request. The applicable tariff provision for each of the solar panels in question (Walara-425-54G3P, Walara-430-54G3P, Walara-570-72G3P, and Walara-575-72G3P) will be 8541.43.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels;…: Photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED): Photovoltaic cells assembled in modules or made up into panels: Crystalline silicon photovoltaic cells of a kind described in statistical note 10 to this chapter.”  The general rate of duty is Free. Effective January 23, 2018, Presidential Proclamation 9693 imposed safeguard measures on imports of crystalline silicon photovoltaic (CSPV) cells and certain products incorporating CSPV cells in the form of additional tariffs or tariff rate quotas for a period of three years. The safeguard measures were subsequently extended by Presidential Proclamation 10339, dated February 4, 2022, for an additional four years.  As a result, products classified under subheading 8541.43, HTSUS, unless specifically excluded, are subject to the additional duties. See Note 18 to Chapter 99 and subheadings 9903.45.21 through 9903.45.27, HTSUS. Regarding the United States-Australia Free Trade Agreement (UAFTA) eligibility: General Note 28(b), HTSUS, sets forth the criteria for determining whether a good is originating under the UAFTA. General Note 28(b), HTSUS, (19 U.S.C. § 1202) states, in pertinent part, that For the purposes of this note, subject to the provisions of subdivisions (c), (d), (m) and (n) thereof, a good imported into the customs territory of the United States is eligible for treatment as an originating good of a UAFTA country under the terms of this note only if - (i) the good is a good wholly obtained or produced entirely in the territory of Australia or of the United States, or both; (ii) the good was produced entirely in the territory of Australia or of the United States, or both, and- (A) each of the non-originating materials used in the production of the good undergoes an applicable change in tariff classification specified in subdivision (n) of this note; (B) the good otherwise satisfies any applicable regional value content requirement referred to in subdivision (n) of this note; or (C) the good meets any other requirements specified in subdivision (n) of this note; and such good satisfies all other applicable requirements of this note; (iii) the good was produced entirely in the territory of Australia or of the United States, or both, exclusively from materials described in subdivision (b)(i) or (b)(ii) of this note; or (iv) the good otherwise qualifies as an originating good under this note, and is imported directly into the customs territory of the United States from the territory of Australia. As the solar panels incorporate non-originating goods/materials, they would have to undergo an applicable change in tariff classification in order to meet the requirements of GN 28(b)(ii). We must refer to GN 28(n) for the specific classification change required. Goods classified in subheading 8541.43.0010, HTSUS, require: “A change to assembled semiconductor devices, integrated circuits or microassemblies of subheading 8541.10 through 8542.90 from unmounted chips, wafers or dice of subheading 8541.10 through 8542.90 or from any other subheading.” Based on the facts provided, the goods described above qualify for UAFTA preferential treatment, because they will meet the requirements of HTSUS General Note 28(b)(ii)(A). All non-originating goods/materials undergo the required tariff shift. The solar panels are therefore eligible for preferential treatment under the UAFTA, upon compliance with all applicable laws, regulations, and agreements. Regarding the Country of origin: The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. The "country of origin" is defined in 19 CFR 134.1(b) as "the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the 'country of origin' within the meaning of this part." The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character or use, different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 69 C.C.P.A. 151 (1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff'd, 989 F.2d 1201 (Fed. Cir. 1993). The solar panels in question are manufactured in Australia from solar cells of Chinese origin. The character of this product is imparted by the Chinese solar cells which would be considered the dominant components of this assembly. The Chinese solar cells have a pre-determined end use when exported from China. The assembly/manufacturing process that takes place in Australia does not change the end use of the solar cells. The solar cells do not under go a substantial transformation as a result of the Australian processing. Therefore, since a substantial transformation does not occur as a result of the Australian processing, the country of origin for marking purposes would be China upon importation into the United States. The solar panel assembly should be legibly, conspicuously, and permanently marked in accordance with the requirements of 19 U.S.C. 1304 to indicate that its country of origin is China. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8541.43.0010, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.02, in addition to subheading 8541.43.0010, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading.  For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at: https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china Additionally, the merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP).  General information regarding the ITA and AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties.  The ITA’s “Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request” is available at https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/current. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division


N342524 September 23, 2024 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.40.0020 Regina Girsh KNS Industries 1005 Virginia Dr. Ft. Washington, PA 19034 RE: The tariff classification of dispensing machines from Taiwan Dear Ms. Girsh: In your letter dated September 9, 2024, you requested a tariff classification ruling. At issue are five series of robotic dispensing machines for surface mount technology (SMT) dispensing operations. The dispensing machines perform various bonding, sealing, and coating applications in connection with the assembly of semiconductors, LEDs, and electronics. They are principally used to apply epoxies, adhesives, solder paste, and other fluid materials in connection with semiconductor device and integrated circuit assembly or “packaging,” including dam and fill, LED encapsulation, Chip Scale Package (CSP), Chip on Board (COB) encapsulation, and ball grid array (BGA) for integrated circuits. The packaging process shields the semiconductor die from physical damage, moisture, and other environmental conditions. All the subject dispensing machines are equipped with fine-tuned valves and nozzles to ensure accurate fluid material deposition. To control of movement of the subject machines' fluid dispenser applicators and ensure the accuracy of dispensation, the units utilize a three-dimensional XYZ coordinate system, representing three axes of motion: horizontal (X), vertical (Y), and depth or height (Z). The GLE/GLLM Robot series is designed for a range of applications in several industries, including SMT glue dot dispensing, module encapsulation, potting, COB encapsulation, component underfill, LCD display, solder paste jetting, camera lens bonding, camera module epoxy sealing, smartphone glass/metal case bonding, dam and fill, and conformal coating. However, you indicate that the principal use of the GLE and GLLM machines is in semiconductor device/LED packaging applications such as underfill and solder paste dispensing. These machines measure (mm) 900 x 1932 x 1920 (W x D x H) and weigh 1300 kg. The SL/SSL Series micro dispensing robotic platforms are specifically designed for semiconductor micro fluid packaging applications for SiP, narrow gap filling, fine line silver paste dispensing, and micro underfill. The SL/SSL Series are designed to accept up to a 12-inch semiconductor wafer. The SL Series measure (mm) 900 x 1850 x 1829 (W x D x H) and weigh 1740 kg. The SSL Series measure (mm) 700 x 1995 x 1756 (W x D x H) and weigh 1050 kg. The XLS Series are robotic dispensing machines for mini/micro-LED packaging applications. The packaging process includes the use of high viscosity optical glue to separate the RGB chips and filling the space (dam) separating the chips with glue. The XLS also supports other semiconductor packaging applications. These machines measure (mm) 1844 x 2859 x 2335 (W x D x H) and weigh 2000 kg. The Model SSD is a dispensing machine designed for lead frame LED encapsulation. The SSD measures (mm) 1256 x 850 x 2338 (W x D x H) and weighs 500 kg. The A Series Desktop Robots, are small-scale dispensing machines, mainly used to produce small quantities as part of the pre-production and semiconductor package testing process in R&D operations. Applications include display panel dispensing, underfill, encapsulation, dam and fill, and silver epoxy & solder paste dispensing. While the use of these machines may vary depending upon the specific R&D applications within a lab setting, the information provided suggests their use is associated principally with semiconductor device/LED or integrated circuit assembly. These machines measure (mm) 870 x 920 x 808 (W x D x H) and weigh 140 kg. The dispensing machines will be imported with dispensing software and post-dispensing automated visual inspection systems (AOI). The software is used to control and manage the dispensing of fluid materials, with features such as remote teaching, motion control, CAD file input, 3D profile printing, automatic dispensing weight measurement and calibration, and AOI. Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS), Statistical Note 1(d), indicates that assembly equipment for semiconductor and integrated circuit assembly machines include dicing, die and wire bonding, as well as packaging equipment “used to encapsulate or package a semiconductor device.” Additionally, the Explanatory Notes to Heading 8486, Section (D) Machines and Apparatus Specified in Note 11(c) to Chapter 84, describe machines and apparatus solely or principally of a kind used for assembling semiconductor devices or integrated circuits as including “encapsulation equipment such as presses for making the plastic casings for chips by pressing plastic material around the chips.” While the subject dispenser machines are used in a range of industries, the information provided indicates that they are generally optimized for, and principally used in, the semiconductor industry to encapsulate and package semiconductor devices or integrated circuits. Accordingly, we find the subject dispensers to be machines of a kind of falling within HTSUS Chapter 84, Note 11(c), covering assembly and packaging machines. The applicable subheading for the GLE/GLLM Robot Series, A Series Desktop Robots, SL/SSL Series, XLS Series, and the Model SSD, imported together with their software, will be 8486.40.0020, which provides for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in note 11(C) to [Chapter 84]; parts and accessories: Machines and apparatus specified in note 11(C) to [Chapter 84]: For assembling semiconductor devices or electronic integrated circuits”. The general rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division


The tariff classification of an Electron Beam Lithography System from Germany


The tariff classification of a focused ion beam nanofabrication system from Germany

machine individual function wafer
semiconductor handling machine


The tariff classification of maskless UV laser beam lithography systems from the Netherlands


N348508 May 22, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.41.0040; 9903.01.25 Gail Duggan Camtek USA, Inc. 1815 NW 169th PL, Suite 1080 Beaverton, OR 97006 RE: The tariff classification of a metrology and inspection machine from Israel Dear Ms. Duggan: In your letter dated May 1, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as the Eagle metrology and inspection machine, which is a device designed for two-dimensional (2D) and three-dimensional (3D) Automatic Optical Inspection (AOI). The Eagle provides comprehensive coverage for semiconductor manufacturing, supporting front-side inspection at sub-micron defect levels, as well as backside and edge inspection. The 3D metrology solution delivers precise measurements for micro-bump coplanarity and height, handling up to 500 million bumps per wafer. The machine is specifically designed to inspect integrated circuits (wafers and chips) and measures features and defects on silicon wafers throughout the manufacturing process of semiconductor devices. The inspection covers the front and mid-end and up to the beginning of the assembly process (packaging and post-dicing). The Eagle is used in semiconductor market segments, including Advanced Interconnect Packaging, Heterogenous Integration, Memory, Complementary Metal-Oxide-Semiconductor (CMOS) Image Sensors, Compound Semiconductors, Micro Electromechanical Systems (MEMS), and Radio Frequency (RF). The Eagle is fully self-sufficient with automatic handling of wafer sizes up to 300mm, including framed wafers. The process flow consists of wafer removal from cassette by robot, pre-alignment, barcode reading, placement on the chuck table, inspection/measurement, removal of the wafer from the chuck table, and placement of the wafer back into the cassette. All data is recorded and saved on computer racks within the system. Measurements take place using various lenses and cameras within the system. Measurements and inspection options included are incoming 2D quality, surface profile, redistribution layer (RDL), epitaxial, backside, backlit, 3D bumps, probe marks, layer thickness, post dicing, inner cracks, re-constructed wafers, edge/bevel, and infrared. The applicable subheading for the Eagle metrology and inspection machine will be 9031.41.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other optical instruments and appliances: For inspecting semiconductor wafers or devices (including integrated circuits) or for inspecting photomasks or reticles used in manufacturing semiconductor devices (including integrated circuits): For inspecting semiconductor wafers or devices: For wafers.” The general rate of duty will be free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 9031.41.0040, HTSUS, listed above. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division


The tariff classification of an electron beam lithography tool from Germany


N349449 June 13, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.20.0000; 9903.01.32 Kristi Culbertson Raith America, Inc. 300 Jordan Road Troy, NY 12180 RE: The tariff classification of the e-LINE Plus 100 electron beam lithography and metrology system from Germany Dear Ms. Culbertson: In your letter dated May 27, 2025, you requested a tariff classification ruling. The Raith e-LINE Plus 100 is an ultra-high-resolution direct write electron-beam (E-beam) lithography and metrology tool designed for high resolution direct write circuit patterning of semiconductor wafer and other resist coated semiconductor materials. It has a 4-inch wafer capability. The e-LINE Plus 100 is also capable of performing nanofabrication applications such as Electron Beam-Induced Deposition (EBID) and etching for direct writing with nanometer resolution. The tool includes scanning-electron-based imaging and metrology for process control. The applicable subheading for the Raith e-LINE Plus 100 will be 8486.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in Note 11(C) to this chapter; parts and accessories: Machines and apparatus for the manufacture of semiconductor devices or of electronic integrated circuits.” The general rate of duty will be free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls in an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.32, in addition to subheading 8486.20.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division


N349451 June 13, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.20.0000; 9902.01.32 Kristi Culbertson Raith America, Inc. 300 Jordan Road Troy, NY 12180 RE: The tariff classification of a hybrid EBL-SEM electron beam lithography system from Germany Dear Ms. Culbertson: In your letter dated May 27, 2025, you requested a tariff classification ruling. The Pioneer Two is a compact electron beam lithography (EBL) system designed for high resolution patterning of semiconductor wafer materials. This direct electron-beam write-on apparatus is designed to write (draw) circuit patterns onto wafers coated with sensitized semiconductor materials. As a hybrid EBL-SEM (scanning electron microscope) system for these semiconductor nanostructures, the Pioneer Two is capable of fabrication (lithography), as well as imaging (electron microscopy), and metrology (measurements using laser interferometer stage) for previously written nanostructures. No separate wafer lifting, handling, loading or unloading equipment is included. The applicable subheading for the Pioneer Two electron beam lithography system will be 8486.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in Note 9 (C) to this chapter; parts and accessories: Machines and apparatus for the manufacture of semiconductor devices or of electronic integrated circuits.” The general rate of duty will be free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls in an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.32, in addition to subheading 8486.20.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division


N349761 June 23, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.90.0000; 9903.01.32 Ressie Thompson Marubeni America Corporation 90 Park Avenue, 6th Floor New York City, NY 11050 RE: The tariff classification of a wafer polishing mounting jig from Japan Dear Ms. Thompson: In your letter dated June 3, 2025, you requested a tariff classification ruling. The product in question is a mounting jig, Model TZ07VL(454-150.3-5)280-PEI. The mounting jig is a flat, round, 1.35mm thick article with a 454mm outer diameter, and is used in Chemical Mechanical Polishing (CMP) machines suitable only for semiconductor wafer polishing applications. The mounting jig can hold up to five silicon carbide (SiC) semiconductor wafers. The mounting jig is comprised of four layers: a frame layer of polyetherimide resin, a surface layer of polyethylene foam, a bonding layer of rubber adhesive and polyethylene terephthalate film (film), and an adhesive layer of acrylic adhesive, film, and cellulose release paper. Each of the mounting jig's five round holes (openings) holds a single wafer for polishing. The wafers are held in place only by the shape of the jig. The mounting jig is attached to the CMP polishing machine by adhesive tape at the bottom of the jig, securing the two together. The mounting jig is specifically shaped and designed to fit the CMP equipment of the customer's specific machine. You state that these CMP machines cannot perform their polishing function without the mounting jig. The applicable subheading for the mounting jig will be 8486.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in Note 11(C) to this chapter; parts and accessories: Parts and accessories.” The general rate of duty will be free. Effective April 5, 2005, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.32, in addition to subheading 8486.90.0000, HTSUS, listed above. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. If the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division


N350440 July 10, 2025 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.90.0000; 9903.01.32 Edward Juliano, Jr. Edward F. Juliano, Jr. - Attorney at Law 303 Wyman Street, Suite 300 Waltham, MA 02451 RE: The tariff classification of an EUV lithography system drive laser module from Germany Dear Mr. Juliano: In your letter dated June 20, 2025, on behalf of your client, ASML US, LLC, you requested a tariff classification ruling. At issue are various units and equipment for ASML's NXE 3800E EUV (Extreme Ultraviolet) semiconductor lithography system, which you state will be imported together and constitute the lithography system's Drive Laser Module. These attached or interconnected units and equipment consist of: radio-frequency (RF) power amplifiers; seed laser module; beam transport system periscope; power distribution system; control cabinet (electric); gas supply system; and cooling system. Also included in the shipment will be certain pre-install items, namely electrical and data cables, hoses for gas supply and cooling, and seismic connectors and vibration dampers. The drive laser is a key component of the EUV lithography system's Light Source module in that it initiates the process of generating EUV light. The drive laser uses the seed laser module and RF power amplifiers to produce high energy pulses that are sent through the beam transport system from the sub-fab up through the floor of the clean room to the Light Source's main module. The Light Source is where the pulses of high energy generated by the drive laser strike droplets of tin, creating a plasma that emits light in the nanometer range. The “periscope” part of the beam transport system contains the mirrors, motors, and other optical elements that allows the high energy pulses to make a 90-degree turn from the Drive Laser Module to the Light Source main module. You suggest that the imported Drive Laser Module equipment constitutes a “functional unit” within the meaning of Section XVI Note 4, Harmonized Tariff Schedule of the United States (HTSUS), and should therefore be classified together as a single machine in subheading 8486.20.0000, HTSUS, providing for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in note 11(C) to this chapter; parts and accessories: Machines and apparatus for the manufacture of semiconductor devices or of electronic integrated circuits.” In support of your position, you cite New York Ruling (NY) N336802, dated Dec. 21, 2023, which determined that a EUV wafer handling module comprised of a FOUP loading dock, atmospheric wafer handler, and a vacuum wafer handler, imported together, to be classified in subheading 8486.40.0030, HTSUS, as a functional unit under Section XVI, Note 4. Section XVI, Note 4 provides that a combination of machines with individual components, whether separate or interconnected, that are intended to contribute together to a clearly defined function covered by one of the headings in Chapter 84 or Chapter 85, are to be classified as a functional unit in the heading appropriate to that clearly defined function. We disagree that the imported equipment, which you collectively refer to as the Drive Laser Module, contributes together to a clearly defined function covered by a heading in Chapter 84 or 85. Rather, this equipment is an integral component of the Light Source. In NY N241695, dated June 6, 2013, we considered the classification of both a complete and incomplete Cymer EUV Light Source for a lithography system. Notably, both the incomplete and complete imported Light Source included a “drive laser” and “beam transport system,” among other components. CBP rejected Cymer's claim that both the complete and incomplete Light Sources were classified as independent “machines” covered by subheading 8486.20.0000. CBP instead determined that the Light Source (whether complete or incomplete) was classifiable as “part” of the lithography system, and properly classified in subheading 8486.90.0000, HTSUS. In the present case, the Drive Laser Module, which includes the beam transport system, RF amplifiers, seed laser module, and supporting power systems, is essentially a subcomponent or subpart of the Light Source, itself a part, rather than a combination of machines with a clearly defined function covered by HTSUS Chapter 84 or 85. Therefore, they do not constitute a functional unit under Section XVI, Note 4. N336902 is inapposite as the clearly defined function of the three units of the module addressed by that ruling are specifically covered in subheading 8486.40.0030, i.e., lifting, handling, and loading of semiconductor wafers. In contrast, the imported Drive Laser Module with its associated units and parts do not have a clearly defined function covered by either Chapter of Section XVI. In sum, the imported Drive Laser Module equipment is essentially a subcomponent or subassembly of a complete Light Source, which itself is a part of the lithography system as per N241695. Accordingly, the imported equipment, entered together, constitutes a part of the NXE 3800E EUV lithography system, which is classifiable in heading 8486. The applicable subheading for the Drive Laser Module, imported together and configured with the components and pre-install equipment described above, will be 8486.90.0000, HTSUS, which provides for parts of machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in note 11(C) to this chapter. The general rate of duty will be free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8486.90.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling's issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division


N352476 September 4, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8541.41.0000; 9903.02.20 Cordell Maines Lumibird Photonics USA, Inc. 49 Willow Peak Drive Bozeman, MT 59718 RE: The tariff classification of QCW laser diode stacks from France Dear Mr. Maines: In your letter dated August 14, 2025, you requested a tariff classification ruling. The merchandise under consideration is described as Quasi-Continuous Wave (QCW) laser diode stacks, Part numbers: PDBX0333, PDBX0507, PDBX0410, PDBX0017. They consist of multiple unmounted laser diodes soldered together on a copper heat sink to form a stack. The subject laser diode stacks are available in different variations with vertical or horizontal light emission and can be mounted using threaded holes, through holes or studs. We note that the laser diode stacks are designed as components for industrial and medical laser systems. The applicable subheading for the QCW laser diode stacks will be 8541.41.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers)…: Photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED): Light-emitting diodes (LED).” The general rate of duty will be Free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 8541.41.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division


N352864 September 15, 2025 CLA-2-85:OT:RR:NC:N2:208 CATEGORY: Classification TARIFF NO.: 8523.51.0000; 9903.01.32 Norman Harris NNR Global Logistics USA Inc. 21023 S Main St Unit D , Carson, CA 90745 RE: The tariff classification of game cartridges from Japan Dear Mr. Harris: In your letter dated August 25, 2025, on behalf of SEGA of America Inc., you requested a tariff classification ruling. The merchandise under consideration is Nintendo Switch game cartridges (game cards), described as "Sonic X Shadow Generations." These Switch game cards are non-volatile flash memory storage devices. Moreover, the subject game cards can be read by a Nintendo Switch system by inserting the card into the system. As per the information provided, these game cards have 32GB of storage and contain the game's complete data, including the game code, textures, models, audio files, and any other assets required for gameplay. The applicable subheading for the subject solid-state non-volatile storage game cartridges will be 8523.51.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Discs, tapes, solid-state non-volatile storage devices, "smart cards" and other media for the recording of sound or of other phenomena, whether or not recorded, including matrices and masters for the production of discs, but excluding products of Chapter 37: Semiconductor media: Solid-state non-volatile storage devices. The rate of duty will be free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Japan will be subject to an additional ad valorem rate of duty of 15 percent. Currently, your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8523.51.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division


N353309 September 22, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8541.29.0075; 9903.01.32 Jiwon Kwon Cusan Customs Service Incorporation #309, 35, Magokjungang 2-ro, Gangseo-gu Seoul 07806 South Korea RE: The tariff classification of GaN Power Transistors from South Korea Dear Ms. Kwon: In your letter dated September 5, 2025, you requested a tariff classification ruling on behalf of your client RFHIC Corporation. The item concerned is a GaN Power Transistor, model IR23220P. This particular transistor is used for wireless communication applications including WiMAX, LTE, WCDMA, and GSM systems. The device has a maximum power dissipation rating of 105W (as specified in the manufacturer's datasheet) and has an operating frequency specification are between s include 2300 and 2400 MHz. The applicable subheading for the GaN Power Transistor, model IR23220P will be 8541.29.0075, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels…: Transistors, other than photosensitive transistors: Other: Other: With an operating frequency not less than 30 MHz. The general rate of duty will be Free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products of South Korea will be subject to an additional ad valorem rate of duty of 15 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8541.29.0075, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling's issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division


C l a s s i f i c a t i o n , O r i g i n

N355286 November 19, 2025 OT:RR:NC:N2:209 CATEGORY: Classification; Origin TARIFF NO.: 8541.43.0010; 9903.02.60; 9903.45.25 Meghann Supino Ice Miller, LLP 1 American Square Indianapolis, IN 46282 RE: The country of origin of solar panels Dear Ms. Supino: In your letter dated October 27, 2025, you requested a classification and country of origin determination on behalf of your client, Precision Enterprise Ltd. The items concerned are two models of solar panels, composed of monocrystalline silicon photovoltaic cells and various other components. The individual identifiers for the solar panels are: 180W Rigid Solar Panel Model No.: FSFP18WM-BL, Lippert no.: 2022001299. 370W Rigid Solar Panel Model No.: FSFP37WM2-BL, Lippert no.: 2022001310. The solar panels are fitted with a junction box, cables and MC4 connectors. In use, the panels would be connected to a solar charging controller, a battery and an inverter, forming a complete solar power system. This ruling only pertains to the solar panel without the additional power managing components. The applicable subheading for each solar panels (180W Rigid Solar Panel Model No.: FSFP18WM-BL, Lippert no.: 2022001299; and 370W Rigid Solar Panel Model No.: FSFP37WM2-BL, Lippert no.: 2022001310) will be 8541.43.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels;…Photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED): Photovoltaic cells assembled in modules or made up into panels: Crystalline silicon photovoltaic cells of a kind described in statistical note 10 to this chapter.” The general rate of duty will be Free. Regarding the country of origin: When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. The manufacturing process of the solar panel is conducted in Taiwan, China and the Philippines. The manufacturing process consists of the following: Taiwan: The monocrystalline silicon solar cells are fully manufactured with a P/N junction. The P/N junction's built-in electric field forces the free electrons to the N-type side and the holes to the P-type side, creating a voltage and, when connected to an external circuit, generating a direct current. This part of the manufacturing process includes wafer selection, texturing, diffusion, etching, film application, printing, sintering, and testing. China: The cells are then shipped to China, where they are soldered to tempered glass, laminated with EVA film and backsheet, and tested. Those components and other components such as aluminum frames, junction boxes, and encapsulants are also sourced from China. Philippines: Final assembly is completed in the Philippines, including framing, junction box assembly with silicon gel, wiring, testing, inspection, and packaging. The finished modules are then shipped to the United States Based upon the facts presented, it is the opinion of this office that the solar cells manufactured in Taiwan impart the essence to the finished solar panels. The raw silicon wafers and other materials undergo a substantial and complex manufacturing process within Taiwan. The Taiwanese manufacturing process results in a functioning solar cells (with the requisite P/N junction) which would be considered an article with a new name, character, and use. The processes performed in China and the Philippines does not substantially transform the solar cells into new and different articles of commerce. As such, the country of origin for marking and trade remedy purposes is Taiwan. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Taiwan will be subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading 8541.43.0010, HTSUS, listed above. Effective January 23, 2018, Presidential Proclamation 9693 imposed safeguard measures on imports of crystalline silicon photovoltaic (CSPV) cells and certain products incorporating CSPV cells in the form of additional tariffs or tariff rate quotas for a period of three years. The safeguard measures were subsequently extended by Presidential Proclamation 10339, dated February 4, 2022, for an additional four years. As a result, products classified under subheading 8541.43, HTSUS, unless specifically excluded, are subject to the additional duties. See Note 18 to Chapter 99 and subheadings 9903.45.21 through 9903.45.27, HTSUS. You have asked whether this product is subject to antidumping duties or countervailing duties (AD/CVD). When there is a question as to whether merchandise is subject to an antidumping or countervailing duty order or considered to be defined by the scope of an order, such a determination is governed by the U.S. Department of Commerce’s International Trade Administration (“Commerce”). Commerce issues scope rulings to determine whether merchandise which is in commercial production is covered by the scope of an antidumping or countervailing duty order. Commerce’s scope rulings are separate and distinct from decisions issued by CBP regarding tariff classification and country of origin for purposes such as duty assessment and marking. To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide to seeking a scope ruling can be found at https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD investigations at the United States International Trade Commission can be viewed on its website at http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits and liquidation can be searched using ACE or CBP’s search tool at https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division


N356337 December 15, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.80.8085 Donal O'Gorman identifyHer Inc. 800 N King Street, Suite 304-3205 Wilmington, DE 19801 RE: The tariff classification of a Peri sensor from China Dear Mr. O'Gorman: In your letter dated November 21, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as a Peri sensor (model IDH-AA-01), which is a battery-powered, body-worn electronic unit that captures bio signals and communicates them via Bluetooth to a paired smartphone application. The device is made of a sealed polymer enclosure with a gasket, an internal printed circuit board assembly (PCBA) carrying a microcontroller with memory, power management integrated circuits (ICs), sensors, and a Bluetooth radio transceiver with antenna. Additionally, there are stainless-steel electrodes, a skin-contact thermistor, an optical window for photoplethysmography (PPG) emitter/detector, and medical-grade adhesive patches for on-body attachment. The device measures 66×45×11 mm and weighs 25 g. The Peri sensor has a PPG (optical) for pulse/flow-related signals, electrodermal activity (EDA) electrodes for skin conductance, a 3-axis accelerometer for motion/posture, and a skin-contact temperature sensor. In operation, the sensors generate analog signals that are digitized by on-board electronics before being wirelessly transmitted via Bluetooth to the paired app. Data is also synced to cloud services where it is processed and the outputs displayed on the app. The Peri sensor is designed as a consumer wellness wearable for trend-tracking of perimenopausal symptom patterns (hot flashes, night sweats, sleep disruption, anxiety) as well as step count and menstrual-cycle tracking. The device is imported with two rechargeable batteries, USB-C charging dock/cable, 20 starter adhesive patches, and a quick-start guide. In your letter, you suggest the applicable heading to be 8517, Harmonized Tariff Schedule of the United States (HTSUS), which provides in relevant part for “…other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network).” The item concerned is primarily used to monitor various aspects of a person's wellbeing. It incorporates various sensors and a processing system that measures health related information. It also has a secondary function of transmitting that data to a remote Bluetooth enabled device which then transmits to a cloud-based service. Classification under heading 8517, HTSUS, is precluded because the devices concerned are composite goods (Section XVI Note 3 and Chapter 90 Note 3) which execute the principal function of determining/calculating a measurement. The ability to transmit that information to a remote device would be considered the unit's secondary or support function. Additionally, as per the Explanatory Notes to heading 8517, carrier-current and other transmitters and receivers which form a single unit with analogue or digital telemetering instruments or apparatus…, are excluded from heading 8517. Measurement apparatus of Chapter 90 are also excluded from classification within Chapter 85. (Section Note XVI Note 1(m)). As such, classification within heading 8517, HTSUS, is not applicable. The applicable subheading for the Peri sensor (model IDH-AA-01) will be 9031.80.8085, HTSUS, which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” The general rate of duty will be free. The tariffs and additional duties cited in the companion information letter are current as of this ruling's issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division


The tariff classification of a pre-installation kit from the Netherlands

semiconductor manufacturing equipment parts


The tariff classification of a lens manipulator module from Germany

machine individual function wafer
photomask
photomask for semiconductor
reticle


N361144May 14, 2026CLA-2:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8486.20.0000 Eunyoung ShimShinhan Customs Service704, Nonhyeon-ro,Seoul 06052South KoreaRE: The tariff classification of an automatic dicing saw from JapanDear Ms. Shim:In your letter dated April 30, 2026 , you requested a tariff classification ruling on behalf of your client,Samsung Medison.The product in question is an automatic dicing saw, model DAD3231, specifically engineered and principallyused for the semiconductor industry. The machine utilizes a high-speed spindle equipped with a circulardiamond blade to singulate individual integrated circuits (die) from a processed silicon wafer. The singulationprocess involves securing the wafer on a vacuum chuck, automatically aligning the cutting path to a precisionof 0.001 mm, and performing a “full-cut” through the wafer using a diamond blade rotating at speeds up to60,000 rpm. The DAD3231 emphasizes high performance and expandability, with an option to handle up to8-inch wafers. Additionally, the DAD3231 has a Y-axis index positioning accuracy of 0.002/210 mm.In your submission, you suggest that the DAD3231 wafer dicing saw is classifiable in subheading8486.40.0020, Harmonized Tariff Schedule of the United States (HTSUS), as a machine for assemblingsemiconductor wafers and semiconductor devices. You assert the dicing saw performs a “back-end”assembly and packaging process, rather than a manufacturing step. We disagree. Singulation completes thephysical fabrication of semiconductor wafers. While the singulation process may also be considered atransition step between manufacturing and assembly, it takes place prior to actual assembly and packagingoperations such as die bonding and encapsulation.This is supported by the Explanatory Notes (EN) to 84.86, Section (B), which specifically lists “laser scribingmachines” and “wafer dicing saws” as examples of machines and apparatus for the manufacture ofsemiconductor wafers, i.e., articles of subheading 8486.20. Furthermore, Section (D) to EN 84.86 coversmachines and apparatus specified in Note 11(C) to Chapter 84, which includes those for assemblingsemiconductor devices (i.e., subheading 8486.40). Section (D) provides some examples of semiconductor assembly and packaging machines and apparatus, including laser engraving machines, encapsulationequipment, and wire bonders. Notable, EN 84.86 Section (D) makes no mention of laser scribing machines orwafer dicing saws. We therefore conclude that the subject wafer dicing saw falls in subheading 8486.20rather than 8486.40. The applicable subheading for the automatic dicing saw, model DAD3231, will be 8486.20.0000, HTSUS,which provides for “Machines and apparatus of a kind used solely or principally for the manufacture ofsemiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays;machines and apparatus specified in Note 11(C) to this chapter; parts and accessories: Machines andapparatus for the manufacture of semiconductor devices or of electronic integrated circuits.” The general rateof duty will be free.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.The holding set forth above applies only to the specific factual situation and merchandise description asidentified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Arthur Purcell at arthur.purcell@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division


The tariff classification of Power Supply Unit Parts Kits from Japan


The tariff classification of sapphire wafers from Japan.

sapphire wafer
synthetic sapphire
synthetic sapphire substrate


NY R02518 September 13, 2005 CLA-2-85:RR:NC:MM:109 R02518 CATEGORY: Classification TARIFF NO.: 8541.60.0060 Mr. Dennis Heck Import Compliance Manager Yamaha Corporation of America 6600 Orangethorpe Avenue P.O. Box #6600 Buena Park, CA 90622-6600 RE: The tariff classification of a crystal quartz resonators and ceramic oscillators from an unspecified country Dear Mr. Heck: In your letter dated August 31, 2005, you requested a tariff classification ruling. You requested the classification of crystal quartz resonators and ceramic oscillators. At the time of your submission, there was not enough descriptive information about the ceramic oscillators in order for this office to determine the proper classification of the merchandise. Therefore, this ruling will only address the classification of the crystal quartz resonators. Below, is a list of questions pertaining to the ceramic oscillators. A response to those questions is needed in order to determine the classification of that merchandise. The crystal quartz resonators are devices that produce or undergo resonance, a condition that exists when inductive reactance equals capacitive reactance. They are used on Yamaha’s 03D digital mixing console. These crystal quartz resonators are mounted and have an operating frequency of 22.579 MHz. There are no other components present within this device, other than the quartz crystal resonator. The applicable subheading for the quartz crystal resonators will be 8541.60.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for “Mounted piezoelectric crystals: Quartz designed for operating frequencies of: Exceeding 20 MHz.” The rate of duty will be free. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Linda M. Hackett at 646-733-3015. You state that the ceramic oscillator is old technology used in Yamaha’s older CD changers and since you only import this type of merchandise when you, occasionally, receive requests for service parts for the older CD changers, you may decide not to pursue a binding ruling on it. However, if you decide to resubmit your request regarding the ceramic oscillators please include all of the material that we have returned to you on that product along with a response to the questions listed below. Your request should make reference to our file number R02518 and be mailed to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section. If your request was submitted electronically and the information required does not involve sending a sample, you can re-submit your request and the additional information electronically. Your submission reveals that the ceramic oscillator is an oscillator circuit with a ceramic resonator. In addition to the ceramic resonator there are passive components such as resistors, capacitors, etc. in the oscillator circuit. 1 - With respect to “etc.” what other components are within the ceramic oscillator? 2 - Please provide a schematic labeling all the components within the ceramic oscillator. 3 - Provide an in-depth explanation of the manufacturing process of the ceramic oscillator, in its exact chronological order. 4 - Any additional information regarding the ceramic oscillator will be appreciated. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division


The tariff classification of Magnesium Fluoride from China


The tariff classification of X-Y In-Circuit Hi-Tester, 1240-02 from Japan


NY R04607 September 7, 2006 CLA-2-90:RR:E:NC:MM:114 R04607 CATEGORY: Classification TARIFF NO.: 9031.49.9000 Ms. Cyndi Eileen Gibbs Managing Partner Gibbs Group, LLC 779 Shasta Street Yuba City, CA 95991 RE: The tariff classification of laser level made in China Dear Ms. Gibbs: In your letter dated August 11, 2006, you requested a tariff classification ruling on a laser level made in China. Descriptive literature and a copy of a photo of the laser level were submitted with the ruling request. The item for which you are requesting a ruling is identified as the RedLINE laser level. The RedLINE is made of impact resistant plastic with rubber shock coating and projects a beam up to 50 feet for leveling purposes. The laser level features a magnetic aluminum base that has been milled for accuracy and a beam that rotates from 0 degrees to 90 degrees. The RedLINE requires two AA batteries to operate; the batteries will be included. You have proposed classification for the RedLINE laser level under subheading 9017.20.50, Harmonized Tariff Schedule of the United States (HTSUS). However, the RedLINE is not classifiable in subheading 9017.50.20 because the laser level is not a pattern generating apparatus designed to produce masks and reticles from photoresist coated substrates. The applicable subheading for the RedLINE laser level will be 9031.49.9000, HTSUS, which provides for measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter: other optical instruments and appliances: other: other. The rate of duty will be 3.5 percent ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Barbara Kiefer at 646-733-3019. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division