Mr. Matt Nakachi
Junker & Nakachi, P.C.
One Maritime Plaza
Suite 825
San Francisco, CA 94111

RE: The tariff classification of a solid-state drive (SSD) from Malaysia and/or China

Dear Mr. Nakachi:

In your letter dated May 7, 2015, on behalf of the SanDisk Corporation, you requested a tariff classification ruling. The submitted sample is being returned.

The merchandise under consideration is a solid-state drive (SSD), the SanDisk U110, which is a flash memory storage device. This SSD contains flash memory components housed in a case that is ready for installation in various types of other host devices, which require data storage such as computers, DVR’s, laptops, et cetera. This SSD is a solid-state non-volatile storage device that is designed to store electronic data using the flash memory semiconductor. It contains a connecting socket (for use in connecting to a host device) incorporated in the same housing, which includes a flash controller in the form of an integrated circuit. The subject SSD does not contain a processor.

The applicable subheading for the subject solid-state drive will be 8523.51.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Discs, tapes, solid-state non-volatile storage devices, "smart cards" and other media for the recording of sound or of other phenomena, whether or not recorded, including matrices and masters for the production of discs, but excluding products of Chapter 37: Semiconductor media: Solid-state non-volatile storage devices. 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 World Wide Web at

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 Lisa Cariello at


Gwenn Klein Kirschner
National Commodity Specialist Division