CLA-2-90:OT:RR:NC:N1:405
Yenkang Liu
Kanaue
2140 Monterey Ave
Santa Clara, CA 95051
RE: The tariff classification of components of an optical inspection system from Japan
Dear Mr. Liu:
In your letter dated April 10, 2017, you requested a tariff classification ruling.
The products at issue in your submission are described as a high intensity light unit and a power control unit intended for use in an automatic optical inspection (AOI) system. The AOI system into which these components are incorporated is designed to inspect semiconductor wafers, photomasks, and the like.
The high intensity light unit, identified by the model number LLR138Fx2106, is designed to provide high intensity linear parallel light (in visible and invisible wavelengths) through specially defined parameters when incorporated into the AOI. When in use, the light unit is placed above a conveyer belt or production line and “illuminates” the device to be inspected as it passes below. A separate imaging head in the system captures an image of the device and enables the AOI system to perform a digital analysis of the product’s quality.
The power control unit, identified by model number LPDCH2LAN-48300NCW-R4, is designed to be used with the high intensity light units. Based on the information provided, it appears that the main function of the power control unit is to convert alternating current (AC) into direct current (DC) and make this current available to the light units when in use. The power control unit has inbuilt controls that enable a user to adjust the level of the output voltage as needed.
Based on the information provided, the complete AOI system into which the high intensity light unit and the power control unit will be incorporated would be considered an optical measuring or checking instrument of subheading 9031.41, Harmonized Tariff Schedule of the United States (HTSUS). Note 2(a) to Chapter 90, which governs the classification of separately imported parts of articles of Chapter 90, indicates that parts and accessories which are goods included in any of the headings of Chapter 84, 85, 91, or elsewhere in 90, are in all cases to be classified in their respective headings (barring three exceptions that don’t apply in this instance). As the high intensity light units are specially designed to be incorporated into the AOI and are not included in any of the headings mentioned by the aforementioned note, they are not excluded from classification as parts of heading 9031. The power control unit, however, is covered by a heading in Chapter 85, and thus would be excluded from classification in 9031 per Note 2(a).
The applicable subheading for the high intensity light unit will be 9031.90.5400, 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: Parts and accessories: Of other optical instruments and appliances, other than test benches: Of optical instruments and appliances of subheading 9031.41 or 9031.49.70. The rate of duty will be free.
The applicable subheading for the power control unit will be 8504.40.9540, HTSUS, which provides for Electrical transformers, static converters…: Static converters: Other: Rectifiers and rectifying apparatus: Power supplies: Other. The rate of duty will be 1.1% 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 https://hts.usitc.gov/current.
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 Evan Conceicao at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division