CLA-2-85:OT:RR:NC:N1:109
Ms. Maria Wood
LSI Corporation
1621 Barber Lane
Milpitas CA 95035
RE: The tariff classification of integrated circuits from Taiwan
Dear Ms. Wood:
In your letter dated January 14, 2010, you requested a tariff classification ruling on three items. The items are two different types of integrated circuits and an evaluation board. You have not furnished adequate information regarding the evaluation board for this office to determine its classification. As such, this ruling will only address the classification of the two integrated circuits. Following the classification of the two integrated circuits you will find a listing of questions that require a response from you in order to provide the classification of the evaluation board.
The merchandise subject to this ruling is two integrated circuits specifically designed for incorporation into mass market hard drives. Each integrated circuit is identified as a system-on-a-chip (SoC). SoC refers to integrating all components of an electronic system into a single integrated circuit. They integrate the functionality of the read channel, hard disk controller, servo logic, microprocessor and memory on a single piece of silicon. It may contain digital, analog, mixed-signal, and often radio frequency functions. In contrast, microcontrollers are typically just single-chip-systems, with lower memory capacity. SoCs are capable of running/operating software with internal or external memory.
The first integrated circuit is a SoC that includes a read channel, a serial physical layer (PHY), a microprocessor core and an HDC core. This SoC will be incorporated into mass market hard drives.
The second integrated circuit is a SoC which includes a read channel, a serial-attached small computer system Interface (SAS) PHY, a microprocessor core and HDC core. This SoC is designed for use in enterprise hard disk drives used in the storage industry.
The applicable subheading for the integrated circuits, whether in die, wafer, or packaged form, will be 8542.31.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electronic integrated circuits: Processors and controllers, whether or not combined with memories, converters, logic circuits, amplifiers, clock and timing circuits, or other circuits." 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 http://www.usitc.gov/tata/hts/.
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 Linda Hackett at (646) 733-3015.
If you decide to resubmit your request for the evaluation board, please refer to our file number N091160 and provide a response the questions listed below. Include all of the material that we have returned to you pertaining to the evaluation board and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section. If your request was submitted electronically and the information required does not involve sending a sample, you can re-submit your request and the additional information electronically.
1. Exactly how does the evaluation board “assist manufacturers in development and performance evaluation” of the SoCs?
2. In operation, what are the inputs in and outputs from this import?
3. If you are familiar with the Atmel RZRaven development kit or similar items, how is this similar to and different from those in regard to use in development?
4. How is its function similar to and different from logic emulation in eemulation and verification engineering (EVE)?
5. What specific performance parameters will the import evaluate? How will the results, if any, be communicated to the manufacturer?
6. Will it identify defective SoCs? If so, how will it do so?
7. Noting your proposed classification under HTSUS 9030, what, if any, electrical quantities, e.g., voltage, current, etc, does it measure and approximately how accurate are those measurements?
8. Noting that you propose classification in HTSUS 9030.90, what device do you consider it to be a part or accessory of? What is the over all function of that device? How does this relate to its functioning?
9. Why do the imports already include a SoC if they are being used in development of the SoC?
10. How do the “peripheral components” on the imported boards, which are apparently not mechanical, “mimic the operation of a hard disk drive”?
11. What is the approximate cost and size (length, width, height) of one of the imports?
12. How many of the imports are needed by the typical manufacturer?
13. Are the imports in any sense prototypes which will enable manufacturers to further develop, test or evaluate the performance of the import (or of the SoC) for use in their products? If so, explain.
If you have any questions regarding the questions the evaluation board, Please contact National Import Specialist James Sheridan (646) 733-3012.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division