CLA-2-90:OT:RR:NC:N1:105
Christine Denny
Qualcomm Inc.
5775 Morehouse Drive
San Diego, California 92121
RE: The tariff classification of an Integrated Development Platform from China.
Dear Ms. Denny:
In your letter dated April 27, 2022, you requested a tariff classification ruling.
The item under consideration is described as an Integrated Development Platform (IDP), which is a device assembly that is used for facilitating integrated circuit (IC or chipset) verification, software development, system level testing, chip circuitry testing, and power measurement. IDPs comprise of multiple circuit card assemblies, or populated printed circuit board assemblies, assembled together in a specially designed, stacked configuration centered around an IC test socket. The test socket is assembled onto the main board of the IDP with additional test ports integrated on both the main and secondary board(s). The mainboard is designed to keep the configuration as universal as possible to enable the testing of current and future chipset model series.
To carry out measurement, checking, and testing activities, a chip is inserted into the main IC test socket and locked in place with a top lid assembly. Electrical currents and signals are then passed through the conductive pins to the IC and then passed back to the board assembly. Measurement and test results performed by the IDP are displayed on an external monitor which is most often connected directly to the board assembly through a display connector. IDPs are also capable of testing chip processing performance for additional component functional controls such as camera modules and sensors by measuring circuitry connections for comparative analysis to pre-defined benchmark parameters. All sensor or camera module checks are in direct relation to the processor integrated circuit’s performance and circuitry power measurement. Any identified faults in the circuitry or chip architecture is addressed by design changes and re-testing on the IDP to validate design changes are viable. IDP devices are used to perform extensive and advanced quantitative electrical testing on chipset circuitry to validate design requirements to assess whether the architecture, Qualcomm software or customer software (or combination thereof) will function as designed. These platform types are used to independently perform testing on the function of chip performance based on predefined parameters and measurable testing of pre-defined performance indicators of Qualcomm chipsets. IDPs feature integrated test sockets for the checking of electrical circuitry within Qualcomm chips. The test socket is used for connecting integrated circuits to the test interface of the IDP’s board assembly by engineers and quality specialists to evaluate chip design integrity. Chips are inserted into the socket and an electrical current is provided through the pin contacts for testing. Testing activities includes evaluating circuit stability and configuration viability testing under simulated environmental strain.
The Integrated Development Platform is substantially similar to the Core Development Platform ruled upon in N325411 (dated April 18, 2022) in that they perform the same principal function but are treated as separate platform types due to differences in board configurations and the setup of the IC test socket during testing. IDPs are more compact in size, feature only one central board, and one or two accessory boards. IDPs, by comparison with the CDP, also feature a manual top lid press for the test socket that allows the user to manually press the chip into the test socket by twisting the handle to make the connection with the socket contacts and hold it in place during testing as opposed to an electronic top lid that presses the chip into the socket as used with CDPs. CDPs are much larger in size and feature multiple populated boards centered around the test socket. In the ruling, CBP found the Core Development Platforms were classified in subheading 9030.82.0000, Harmonized Tariff Schedule of the United States (HTSUS).
Accordingly, as you suggest in your letter, the applicable subheading for the Integrated Development Platform is 9030.82.0000, HTSUS, which provides for “Oscilloscopes, spectrum analyzers and other instruments and apparatus for measuring or checking electrical quantities, excluding meters of heading 9028; instruments and apparatus for measuring or detecting alpha, beta, gamma, X-ray, cosmic or other ionizing radiations; parts and accessories thereof: Other instruments and apparatus: For measuring or checking semiconductor wafers or devices (including integrated circuits).” The general rate of duty is free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9030.82.0000, 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 9030.82.0000, 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 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