CLA-2-85:OT:RR:NC:N2:209
Seokwoo Jang
Samsung Electro-Mechanics
150, Maeyeong-ro, Yeongtong-gu, Suwon-si, Gyeonggi-do
Suwon-si, 16674
Republic of Korea
RE: The tariff classification of printed circuit substrates from South Korea
Dear Mr. Jang:
In your letter dated May 2, 2022, you requested a tariff classification ruling on printed circuit substrates.
The items concerned are referred to as the FCCSP (Flip Chip Chip Scale Package) and the FCBGA (Flip Chip Ball Grid Array).
The FCCSP (Flip Chip Chip Scale Package) is a substrate used in the manufacture of application processors. It is a connection path for electrical signals between the IC and the main board (PCB). It is a structure that converts the fine wiring of the IC into the range of the main PCB. The substrate is made of an insulating material with excellent cooper adhesion to realize fine circuit line width. A printing process is used to create the circuit element and pathways. There are no active or passive electrical elements formed during the printing process nor are there any discrete active or passive electrical elements incorporated into this printed circuit at time of import into the United States.
The FCBGA (Flip Chip Ball Grid Array) is a substrate for a CPU. It is a connection path for electrical signals between the IC and the main board (PCB). It is a structure that converts the fine wiring of the IC into the range of the main PCB. The substrate is made of an insulating material with excellent cooper adhesion to realize fine circuit line width. The printing process is used to create the circuit element and pathways. There are no active or passive electrical elements formed during the printing process. There are discrete (separately produced) capacitors mounted to this printed circuit at time of import into the United States.
You have proposed that both items are classifiable as parts within subheading 8542.90.0000, Harmonized Tariff Schedule of the United States (HTSUS). While we agree that both items could be considered “parts”, we apply Section XVI Note 2(a) to determine the classification of “parts”. The FCCSP (Flip Chip Chip Scale Package) is provided for within its own heading. As it is a bare printed circuit formed on an insulating base, heading 8534, HTSUS, would take precedence over a parts provision. As such subheading 8542.90.0000, HTSUS would be inapplicable for this item.
The applicable subheading for the FCCSP (Flip Chip Chip Scale Package) will be 8534.00.0070, HTSUS, which provides for “Printed circuits: Plastics impregnated, not flexible: Other”. The rate of duty will be Free.
The applicable subheading for the FCBGA (Flip Chip Ball Grid Array) will be 8542.90.0000, HTSUS, which provides for “Electronic integrated circuits; parts thereof: Parts”. The 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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division