CLA-2-34:OT:RR:NC:N3:136
Tomoko Hara
Resonac America, Inc
2150 N. First Street, Suite 350
San Jose, CA 95131
RE: The tariff classification of Chemical Mechanical Planarization (CMP) Slurries from Japan
Dear Mr. Hara:
In your letter dated May 15, 2025, you requested a tariff classification ruling on Chemical Mechanical
Planarization (CMP) Slurries.
In your request, the four subject products are described as Chemical Mechanical Planarization (CMP)
Slurries. You explain that in the semiconductor industry, CMP slurries are used in silicon wafer production to
polish semiconductor wafers to a flat, smooth surface. CMP slurries help to level the surface between
different layers of materials, ensuring proper electrical connections of semiconductor chips. You state that
CMP slurries are specialized liquid mixtures of abrasive particles, chemicals and purified water.
The products at issue are identified as follows:
HS-3PN605-1: Nickel Palladium Layer polish, x 3 concentration
HS-3T805-3: Copper Layer polish, x 3 concentration
HS-7T915-1: Copper Layer polish, x 7 concentration
HS-9550: Silicon Oxide Layer polish, x 3 concentration
The applicable subheading for the four Chemical Mechanical Planarization (CMP) Slurries will be
3405.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Polishes and
creams, for footwear, furniture, floors, coachwork, glass or metal, scouring pastes and powders and similar
preparations (whether or not in the form of paper, wadding, felt, nonwovens, cellular plastics or cellular
rubber, impregnated, coated or covered with such preparations), excluding waxes of heading 3404: Other.
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
3405.50.0000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Nuccio Fera at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division