CLA-2-90:OT:RR:NC:N1:105
Melissa Simington
Qualcomm
5775 Morehouse Drive
San Diego, California 92121
RE: The tariff classification of the Cohu Ismeca NY32 from Malaysia
Dear Ms. Simington:
In your letter dated May 8, 2020, you requested a tariff classification ruling.
The item under consideration is the Cohu Ismeca NY32, which is a 32-position turret platform for integrated circuit (“IC”) testing, optical inspection and packing fully integrated into a single process. The process integration enables the equipment to perform extended autonomous operations throughout the multi-step quality procedure. The turret handler features functionality to perform extensive optical inspections but does not perform electrical testing without the connection to the customer’s external devices.
The Cohu NY32 system starts operation with the input of either 30 thin JEDEC or 20 thick JEDEC trays of untested IC’s loaded into the testing sequence automatically by the front-loading handler module. The process flow proceeds directly to the first phase of optical inspection which includes presence of the part, part orientation with correction, part boundary location detection to prevent damage when placing into the test cycle, and axis position inspection with automated feedback for position correction. Mark inspections are then performed if all parts are in pass status following initial inspection which includes visual scan confirmation of the presence or absence of user defined parameters, the integrity of the user defined marking, OCR inspection which reads and returns to the machine the character sequence as compared to the user defined requirements. In addition, a scan is performed for traceability in relation to barcode or 2D matrix ID. Following a pass status of the marking inspection sequence all parts then proceed to 2D inspection which conducts measurement checks on pad pitch, width, length, grid position, offset, and bridge as well as a 2D body measurement inspection of part body width and length. The system proceeds with extensive 2D bottom, front and side view optical inspections of the pad and body surfaces. A 3D Flex optical inspection station is also integrated into the system for 3-dimensional surface examination to check the coplanarity, height and appearance of the solder balls on the bottom of the product with the use of high-resolution cameras.
The inspections employ fully integrated color cameras with an optimized lighting system which can identify appearance defects of the product including overflow or damage to the substrate, chips, voids, blistered surfaces, scratches, cracks, and the presence of foreign material. Additional surface inspections are performed which include mold surface inspection to identify the previously listed defects in conjunction with dedicated camera identification for the presence of exposed copper. Throughout all testing processes, the IC products do not physically leave the handler. The system assigns a rejection notification to any IC’s that do not conform to the user specified conditions regarding size, shape, orientation, surface quality or composition integrity.
Once inspection processes are completed all post-tested products are moved to a full finishing process by the throughput turret handler transferring the products from the testing belt to a dedicated output module. Similar to the device in ruling NY G86065 (dated January 25, 2001), products are then sorted by a pass or reject categorization following a completed inspection sequence.
Based on the information provided, we find that the Cohu Ismeca NY32 is a composite machine. Note 3 to Chapter 90, Harmonized Tariff Schedule of the United States (HTSUS), states “The provisions of notes 3 and 4 to section XVI apply also to this chapter.” Note 3 to Section XVI HTSUS provides as follows:
Unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function.
We find that the Cohu Ismeca NY32’s ability to optically inspect integrated circuits is the principal function of the device. The ability to sort and package the units that pass the inspection are considered secondary features.
The applicable subheading for the Cohu Ismeca NY32 will be 9031.41.0060, 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 or for inspecting photomasks or reticles used in manufacturing semiconductor devices: For inspecting semiconductor wafers or devices: 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 the 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division