CLA-2-85:OT:RR:NC:N2:212

Regina Girsh
Kulicke & Soffa Industries, Inc.
1005 Virginia Drive
Fort Washington, PA 19034

RE: The tariff classification of a vision processing system from China

Dear Ms. Girsh:

In your letter dated June 7, 2021, you requested a tariff classification ruling.

The merchandise under consideration is identified as the Matrox Box, which is described as a vision processing system for use with ball-bonding manufacturing devices. The subject device is comprised of a motherboard, CPU, hard drive, and vision peripherals enclosed within a metal housing. The device is specifically designed to be incorporated within the aforementioned ball-bonding machine where it is attached to a high-speed camera, which we note is not imported with the device and not subject to this request.

Based upon the information provided, the vision processing system, when attached within the ball-bonding machine, captures images produced by the camera. The device then processes that information using pattern recognition software in order to determine the correct location for a wire to be bonded to a leadframe or substrate within the manufacturing of semiconductors and other electrical products. The system is capable of storing this location and execution information for future manufacturing scenarios.

The applicable subheading for the Matrox Box will be 8543.70.9960, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8543.70.9960, 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., 9903.88.02, in addition to subheading 8543.70.9960, 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, including information on exclusions and their effective dates, 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 https://www.cbp.gov/trade/remedies/301-certain-products-china

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 Luke LePage at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division