CLA-2-84:OT:RR:NC:N1-104
Kristi Culbertson
Raith America, Inc.
300 Jordan Road
Troy, NY 12180
RE: The tariff classification of an Electron Beam Lithography System from Germany
Dear Ms. Culbertson:
In your letter dated April 16, 2025, you requested a tariff classification ruling.
The VOYAGER product is an electron beam lithography (EBL) nanolithography tool, also referred to as an
e-beam writer. You state that the VOYAGER is specifically designed and principally used for lithograph
patterning of semiconductor devices. It is also suitable for use in the fabrication of integrated circuits,
photonic components, microelectromechanical systems (MEMS), and producing semiconductor device
prototypes and small-batch specialized components. Highly focused electron beams are employed to directly
(without a mask) draw patterns on the nanometer scale onto semiconductor devices and other resist-coated
substrates.
The VOYAGER operates with a beam energy range between 10-15 kV. The core system components are: (1)
electron beam column; (2) electron optics system; (3) pattern generator; (4) laser interferometer X-Y-Z
positioning stage; (5) vacuum system; and (6) control system consisting of a Window 10-based workstation
running Raith NanoSuite and optional ErgoFlow software. Also included are the system housing and
environmental controls consisting of a thermal and acoustic shielding enclosure for the EBL system, separate
enclosures for the electronic control systems, and integrated chillers to control the temperature of system
components. The machine’s chamber measures 500mm x 440mm x 300mm (W x D x H).
The applicable subheading for the VOYAGER EBL nanolithography system will be 8486.20.0000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and apparatus of a
kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor
devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in Note 11(C)
to this chapter; parts and accessories: Machines and apparatus for the manufacture of semiconductor devices
or of electronic integrated circuits.” The general rate of duty will be free.
Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs. All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries (including Germany) will be subject to an additional 10 percent ad valorem rate of duty. Your
product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8486.20.0000, HTSUS,
listed above.
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 at https://hts.usitc.gov/.
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 the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. If 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 and Border Protection
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, please contact
National Import Specialist Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division