CLA-2-85:OT:RR:NC:N1:109

Ms. Suzett Lopez
Custom Sensors & Technologies, Incorporated
14401 Princeton Avenue
Moorpark, CA 93021

RE: The tariff classification of Hybrid-Pressure Die Assemblies (“303-“) from Mexico

Dear Ms. Lopez:

In your letter dated May 2, 2012 you requested a tariff classification ruling.

The merchandise subject to this ruling is Hybrid-Pressure Die Assemblies (“303-“). They operate within Kavlico Corporation’s “303-” product family of top level electrical pressure transducers to detect the variations of the electrical changes (resistance). These assemblies incorporate a pressure die (considered the “eyes” of the transducer) that is deflected when directly exposed to pressure via a semiconductor based diaphragm. This deflection produces a piezo-resistive effect on the material and changes the values of four resistors (passivated or etched on the semiconductor diaphragm) connected in a balanced bridge configuration. The changes in resistance of each passivated or etched resistor unbalance the bridge producing a (“raw” electrical signal) resistance output variation. This resistance variation is then detected by a microcontroller, which through embedded software interprets the resistive signal provided by the pressure die into a conditioned voltage output considered the “brain” of the transducer.

The manufacturing process of the Hybrid-Pressure Die Assemblies (“303-“) begins with a ceramic insulating substrate upon which a thick film circuit is formed directly on the substrate using screen printing technology. Passive elements in the form of interconnection paths or conductors are produced at the same time as the thick film circuitry on the same insulating substrate. Discrete active components, a piezo resistive transducer (PRT) and a microcontroller (integrated circuit), and discrete passive components, a resistor and a capacitor, which were created through semiconductor technology, are mounted onto the same insulating substrate.

The purpose of the interconnections of these hybrid integrated circuits is to provide electrical connectivity between the discrete active and passive components. The PRT reacts to changes in pressure and converts the pressure into resistance. The microcontroller reads the variations on resistance provided by the PRT and transforms those variations into digital signals by converting them in an analog signal (voltage). The resistors limit the electrical current directed to the microcontroller. The capacitors function as filters for the voltage that feed the microcontroller.

The manner in which the Hybrid-Pressure Die Assemblies (“303-“) are manufactured meets the definition of a hybrid integrated circuit in accordance with Legal Note 8 (b) (ii) to Chapter 85 of the Harmonized Tariff Schedule of the United States (HTSUS).

The applicable subheading for the Hybrid-Pressure Die Assemblies (“303-“) will be 8542.39.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electronic integrated circuits: 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 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 Linda M. Hackett at (646) 733-3015.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division