CLA-2-84:OT:RR:NC:N1:104
Kristi Culbertson
Raith America, Inc.
300 Jordan Road
Troy, NY 12180
RE: The tariff classification of maskless UV laser beam lithography systems from the Netherlands
Dear Ms. Culbertson:
In your letter dated April 23, 2025, you requested a tariff classification ruling.
The PICOMASTER Standard Series consists of five models of focused UV laser beam systems for
semiconductor lithography and microelectronic/nanofabrication applications: PICOMASTER Start100,
PICOMASTER100, PICOMASTER150, PICOMASTER200, and PICOMASTER350. The Standard Series
models employ a single focused laser beam to directly (i.e., without a photomask) draw or “write” patterns on
the nanometer scale onto semiconductor devices and other photosensitive substrate materials. The Standard
Series models are designed for and principally used in semiconductor manufacturing (mask creation, direct
writing on semiconductor materials), photonics (fabrication of optical components), LED manufacturing, flat
panel display patterning, MEMS/NEMS (fabrication of micro/nano-electromechanical systems),
microfluidics, and RF device component creation.
The key components of the PICOMASTER Standard Series machines include: (1) main housing; (2) writing
module consisting of GaN laser diode source and high-precision optical components including beam shaping
optics; (3) positioning system (air bearing stages, linear motors, optical encoders with nanometer resolution);
(4) control electronics; (5) and environmental controls (HEPA filter, temperature and humidity control
systems).
The applicable subheading for all five models of the PICOMASTER Standard Series machines 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 the Netherlands) 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