CLA-2-85:OT:RR:NC:N2:212
Goran Bulaja
Platit Inc.
1312 Armour Blvd.
Mundelein, IL 60060
RE: The tariff classification of PVD heat shields from the Czech Republic
Dear Mr. Bulaja:
In your letter dated September 12, 2025, you requested a tariff classification ruling.
There are five items at issue with this request, which are all described as stainless steel mesh shields used in
specific physical vapor deposition (PVD) machines. The individual shields are identified and described
further as follows:
12-16-000192: used with the PI311 machine
12-16-000227: used with the PI411 machine
12-16-000212: used with PI411 machine
12-16-000392: used with PI111 machine
12-16-000190: used with PI80 machine
The subject shields are specifically designed and shaped to fit within the above referenced PVD machines
and protect the specific heating element by preventing dust and other particles from accumulating on the
target item. Based upon the information provided, these heat shields are cut and shaped to specified
dimensions to fit only within the noted machine. As such, it is our view that they are considered parts of
those machines.
The applicable subheading for the mesh shields, part numbers 12-16-000192, 12-16-000227, 12-16-000212,
12-16-000392, and 12-16-000190, will be 8543.90.1200, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified
or included elsewhere in this chapter; parts thereof: Parts: Of physical vapor deposition apparatus of
subheading 8543.70.” 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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 8543.90.1200, 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 Luke LePage at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division