CLA-2-85:OT:RR:NC:N2:220
Regina Girsh
KNS Industries
1005 Virginia Dr.
Fort Washington, PA 19034
RE: The tariff classification of an electrical controller from the Netherlands
Dear Ms. Girsh:
In your letter dated November 5, 2024, you requested a tariff classification ruling.
The first item under consideration is identified as the AX Placement Controller, PN 4022-591-01128, which is described as an enclosure having a printed circuit board assembly (PCBA) and an internal power supply. The Placement Controller is designed to control the placement of components in a surface mount (SMT) production machine, where individual components are selected and placed onto a circuit board in preparation for soldering. The Placement Controller, which is said to operate at 230 V, takes sensor and camera inputs, along with programmed component mapping of the specific board being assembled, and controls the operation and function of four electric motors and the robotic arm’s placement head.
The second item under consideration is identified as the AX Transport Controller, PN 4022-594-15706, which is described as an enclosure having a control board PCBA, a power board PCBA, relay boards, a power supply and cooling fans. The Transport Controller controls the transport device so it will guide the printed circuit boards to its exact location in the SMT machine for component placement.
We note that both controllers have onboard processors, memory, multiple inputs and outputs, and both send and receive position and control data to/from a host system. Furthermore, both controllers are responsible for the electrical control and positioning of other machines and apparatus, namely the robotic arm and the transport. While these electrical control machines do control electric motors, their principal use is to control system functionality and/or process control, which you refer to them as embedded process controllers and not specifically motor controllers.
The applicable subheading for the AX Placement Controller, PN 4022-591-01128, and the AX Transport Controller, PN 4022-594-15706, will be 8537.10.9160, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity, …: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem.
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.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division