CLA-2-84:OT:RR:NC:N1:104
Ressie Thompson
Marubeni America Corporation
90 Park Avenue, 6th Floor
New York City, NY 11050
RE: The tariff classification of a wafer polishing mounting jig from Japan
Dear Ms. Thompson:
In your letter dated June 3, 2025, you requested a tariff classification ruling.
The product in question is a mounting jig, Model TZ07VL(454-150.3-5)280-PEI. The mounting jig is a flat,
round, 1.35mm thick article with a 454mm outer diameter, and is used in Chemical Mechanical Polishing
(CMP) machines suitable only for semiconductor wafer polishing applications. The mounting jig can hold up
to five silicon carbide (SiC) semiconductor wafers.
The mounting jig is comprised of four layers: a frame layer of polyetherimide resin, a surface layer of
polyethylene foam, a bonding layer of rubber adhesive and polyethylene terephthalate film (film), and an
adhesive layer of acrylic adhesive, film, and cellulose release paper. Each of the mounting jig’s five round
holes (openings) holds a single wafer for polishing. The wafers are held in place only by the shape of the jig.
The mounting jig is attached to the CMP polishing machine by adhesive tape at the bottom of the jig,
securing the two together. The mounting jig is specifically shaped and designed to fit the CMP equipment of
the customer’s specific machine. You state that these CMP machines cannot perform their polishing function
without the mounting jig.
The applicable subheading for the mounting jig will be 8486.90.0000, 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:
Parts and accessories.” The general rate of duty will be free.
Effective April 5, 2005, 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 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 8486.90.0000, 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division