CLA-2-85:OT:RR:NC:N2:212

Magdalena Banko
Princeton Scientific Corporation
3201 Highfiled Drive, Suite H
Bethlehem, PA 18020

RE: The tariff classification of a physical vapor deposition device from Turkey

Dear Ms. Banko:

In your letter dated November 20, 2025, you requested a tariff classification ruling.

The merchandise under consideration is identified as the High-Power Impulse Magnetron Sputtering (HiPIMS) system, part number HiPIMS-200. The subject device is further described as a physical vapor deposition (PVD) apparatus used to deposit thin-film coating onto various substrates. The machine is presented as a complete system comprised of various modules and chambers used to perform the necessary functions. These modules include a magnetron, deposition chamber, vacuum pumping system, and electrical controllers.

The PVD system operates by creating a vacuum within the chamber, which is filled with a specific gas to be ionized. The article to be coated is placed within the chamber between an anode and a cathode. An electrical voltage is applied between the anode and cathode causing the gas to be ionized. The ionized particles are directed to the item via the magnetron, causing it to be coated with the substance. The device is used to coat various items within a laboratory, testing, or industrial prototype environments.

In your request, you suggest that the correct classification for the subject device should be 8543.70.2000, Harmonized Tariff Schedule of the Untied States (HTSUS). We agree.

The applicable subheading for the HiPIMS-200 will be 8543.70.2000, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Physical vapor deposition apparatus.” The general rate of duty will be 2.5% ad valorem.

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 Turkey 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. 9903.02.64, in addition to subheading 8543.70.2000, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division