CLA-2-84:OT:RR:NC:N4:120
Mr. Tim Davis
Micron Technology, Inc.
590 Alder Drive
Milpitas, CA 95131
RE: The tariff classification of an ADP memory unit.
Dear Mr. Davis:
In your letter dated September 30, 2015, you requested a tariff classification ruling on merchandise which you plan to export. A sample was submitted with your letter and will be returned.
The merchandise under consideration is identified by you as the “Hybrid Memory Cube” (HMC). This device is comprised of four Dynamic Random Access Memory (DRAM) dies containing 256 memory banks, and one logic die (memory controller). You state that the HMC was developed to replace the memory module of an automatic data processing (ADP) machine’s main memory and is designed to be used solely or principally with an ADP machine.
The intended use of the HMC is to be surface mounted to the motherboard of a central processing unit (CPU), to provide the working memory for the application software and drivers that enable the peripheral devices of the ADP system to operate. The HMC contains the memory controller and interfaces directly with the host CPU to which it’s connected. As such, the HMC meets Note 5C to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS), with regard to ADP units.
In your letter, you state that the Hybrid Memory Cube is manufactured in the United States and will be exported to undisclosed countries. Please be advised that classification rulings issued by this office are applicable to the product in question when imported into the United States. Since you plan to export this product, it is recommended that you seek a ruling from the designated customs service of that country prior to export.
The applicable subheading for the Hybrid Memory Cube will be 8471.80.4000, HTSUS, which provides for “Automatic data processing machines and units thereof…Other units of automatic data processing machines: Other: Units suitable for physical incorporation into automatic data processing machines.”
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 Karl Moosbrugger at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division