CLA-2-90:OT:RR:NC:N1:105
Gail Duggan
Camtek USA, Inc.
1815 NW 169th PL, Suite 1080
Beaverton, OR 97006
RE: The tariff classification of a metrology and inspection machine from Israel
Dear Ms. Duggan:
In your letter dated May 1, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the Eagle metrology and inspection machine, which is a device
designed for two-dimensional (2D) and three-dimensional (3D) Automatic Optical Inspection (AOI). The
Eagle provides comprehensive coverage for semiconductor manufacturing, supporting front-side inspection
at sub-micron defect levels, as well as backside and edge inspection. The 3D metrology solution delivers
precise measurements for micro-bump coplanarity and height, handling up to 500 million bumps per wafer.
The machine is specifically designed to inspect integrated circuits (wafers and chips) and measures features
and defects on silicon wafers throughout the manufacturing process of semiconductor devices. The inspection
covers the front and mid-end and up to the beginning of the assembly process (packaging and post-dicing).
The Eagle is used in semiconductor market segments, including Advanced Interconnect Packaging,
Heterogenous Integration, Memory, Complementary Metal-Oxide-Semiconductor (CMOS) Image Sensors,
Compound Semiconductors, Micro Electromechanical Systems (MEMS), and Radio Frequency (RF).
The Eagle is fully self-sufficient with automatic handling of wafer sizes up to 300mm, including framed
wafers. The process flow consists of wafer removal from cassette by robot, pre-alignment, barcode reading,
placement on the chuck table, inspection/measurement, removal of the wafer from the chuck table, and
placement of the wafer back into the cassette. All data is recorded and saved on computer racks within the
system. Measurements take place using various lenses and cameras within the system. Measurements and
inspection options included are incoming 2D quality, surface profile, redistribution layer (RDL), epitaxial,
backside, backlit, 3D bumps, probe marks, layer thickness, post dicing, inner cracks, re-constructed wafers,
edge/bevel, and infrared.
The applicable subheading for the Eagle metrology and inspection machine will be 9031.41.0040,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking
instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors;
parts and accessories thereof: Other optical instruments and appliances: For inspecting semiconductor wafers
or devices (including integrated circuits) or for inspecting photomasks or reticles used in manufacturing
semiconductor devices (including integrated circuits): For inspecting semiconductor wafers or devices: For
wafers.” 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. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
9031.41.0040, 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 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 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 Jason Christie at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division