CLA-2-90:OT:RR:NC:N3:135
Mr. Aaron Marx
Crowell & Moring, LLP
1001 Pennsylvania Ave NW
Washington, DC 20004
RE: The tariff classification of an electronic module assembly from China
Dear Mr. Marx:
In your letter dated January 2, 2020, you requested a tariff classification ruling on behalf of Siemens Medical Solutions USA, Inc.
The subject product is identified as an “Electronic Module Assembly” (“E-Chassis”) designed solely for use with medical ultrasound systems. The Electronic Module Assembly is a tested but incomplete electronic module that needs to be further processed in the United States into a complete electronic module, which will be used as a core element of a finished ultrasound imaging system. The imported item consists of (1) circuit boards, (2) a real-time manager assembly (including a commercial computer motherboard, CPU, hard drive, and video card), (3) a “backplane” (a circuit board that connects the various system boards), (4) a “cardcage” (a mechanical structure to which the backplane is bolted), (5) a “continuous beamformer” used for Doppler imaging to depict both visual images and audio interpretation of blood flow, (6) a power supply system, and (7) a trolley frame assembly (the structure that houses the CPU and that ultimately will house the other components after importation into the United States (i.e., a monitor, a control panel, connection cables, transducers, etc.).
The applicable subheading for the Electronic Module Assembly will be 9018.19.9560, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences …: [e]lectro-diagnostic apparatus …: [o]ther: [o]ther: [o]ther: [p]arts and accessories.” The general rate of duty will be free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9018.19.9560, 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., 9903.88.01, in addition to subheading 9018.19.9560, 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 trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, 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 and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division