CLA-2-85:OT:RR:NC:N2:212
Jeonghye Kim
Point Engineering Co.,the Ltd.
89, Asanvalley-ro, Dunpo-myeon
Asan-si 31409
South Korea
RE: The tariff classification of probe pins from South Korea
Dear Jeonghye Kim:
In your letter dated September 16, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as a Micro-Electrical Mechanical System (MEMS) probe
pin, which you state is an electrical contact terminal used with probe cards. A probe card is a device that tests
the quality of semiconductor wafers and chips, checking for defects. The subject pin is composed of
palladium cobalt, gold, palladium, copper, and rhodium and measures 4.4 millimeters in length and 56
micrometers in diameter. The pin, when attached to the probe card, makes direct electrical contact with the
wafer or chip that is being tested.
In your request, you suggest that the correct classification for the subject device should be 8536.90.9090,
Harmonized Tariff Schedule of the United States (HTSUS). This is not a valid 10-digit classification within
the HTSUS. However, we agree with the noted subheading up to the sixth digit. An examination of the text
within subheading 8536.90, HTSUS, reveals reference to “wafer probers,” which we find to be an accurate
description of the subject articles.
The applicable subheading for the MEMS probe pin will be 8536.90.4000, HTSUS, which provides for
“Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in
electrical circuits…for a voltage not exceeding 1,000 V…: Other apparatus: Terminals, electrical splices and
electrical couplings; wafer probers.” 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 South Korea
will be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.56, in addition to subheading
8536.90.4000, 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