CLA-2-90:OT:RR:NC:N2:212
Michael Roll
Roll & Harris LLP
1999 Avenue of the Stars
Los Angeles, CA 90067
RE: The tariff classification of a TFT-LCD Module from China
Dear Mr. Roll:
In your letter dated July 3, 2020, you requested a tariff classification ruling on behalf of your client, JDI Display America, Inc.
The merchandise under consideration is described as thin film transistor (TFT) – liquid crystal display (LCD) module. The module consists of a completed LCD cell, drive and control circuits, and a flexible printed circuit board to connect the device to the host unit. The module is meant to be incorporated into the rearview mirror of an automobile in order to display information such as speed, RPM, direction, camera images, and navigation information. As such, the subject item is cut to a specific shape and size to fit within an existing rearview mirror. Further, the flexible connector is specifically designed to connect to the vehicle’s electronic system.
In your request, you suggest that the subject modules are correctly classified under subheading 9013.80.7000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the TFT-LCD module will be 9013.80.7000, HTSUS, which provides for “Liquid crystal devices not constituting articles provided for more specifically in other headings; lasers, other than laser diodes; other optical appliances and instruments, not specified or included elsewhere in this chapter; parts and accessories thereof: Other devices, appliances and instruments: Flat panel displays other than for articles of heading 8528, except for subheadings 8528.52 or 8528.62.” The general rate of duty will be free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9013.80.7000, 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 9013.80.7000, 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 Section 301 trade remedy, 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 https://www.cbp.gov/trade/remedies/301-certain-products-china
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 Luke LePage at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division