Ms. Allison Kepkay
White & Case LLP
701 Thirteenth Street, NW
Washington, DC 20005-3807

RE: The tariff classification of Solid State Drives (SSDs) from various countries

Dear Ms. Kepkay:

In your letter dated August 14, 2018, on behalf of Toshiba Memory America, Inc. (TMA), you requested a tariff classification ruling. The provided samples are being returned.

The merchandise under consideration is Solid State Drives (SSDs), including TMA's Enterprise SSDs (PM Series, RM Series, CM Series, CD Series, and HK Series), Client SSDs (XG Series, BG Series (those with connecting sockets), SG Series, and HG Series), and OCZ SSDs (RC Series, TR Series, and XS Series), which are flash memory storage devices designed to be incorporated into laptops, desktops, tablets, and other electronic devices. The subject SSDs have no mechanical moving parts and are used to store or transmit data. Moreover, these SSDs are non-volatile data storage devices comprised of Electrically Erasable Programmable Read-Only Memory ("EEPROM" or "E2PROM") in the form of integrated circuits mounted on a printed circuit board and incorporate a connecting socket to a host appliance. Furthermore, they use only power supplied from the systems to which they are connected, and require no battery.

The applicable subheading for the subject SSDs is 8523.51.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Discs, tapes, solid-state non-volatile 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 the 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


Steven A. Mack
National Commodity Specialist Division