CLA-2-84:OT:RR:NC:N1:104
Kristi Culbertson
Raith America, Inc.
300 Jordan Road
Troy, NY 12180
RE: The tariff classification of a hybrid EBL-SEM electron beam lithography system from Germany
Dear Ms. Culbertson:
In your letter dated May 27, 2025, you requested a tariff classification ruling.
The Pioneer Two is a compact electron beam lithography (EBL) system designed for high resolution
patterning of semiconductor wafer materials. This direct electron-beam write-on apparatus is designed to
write (draw) circuit patterns onto wafers coated with sensitized semiconductor materials. As a hybrid
EBL-SEM (scanning electron microscope) system for these semiconductor nanostructures, the Pioneer Two
is capable of fabrication (lithography), as well as imaging (electron microscopy), and metrology
(measurements using laser interferometer stage) for previously written nanostructures. No separate wafer
lifting, handling, loading or unloading equipment is included.
The applicable subheading for the Pioneer Two electron beam lithography 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 9 (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. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. Your product falls in 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.
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 Arthur Purcell at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division