CLA-2-90:RR:NC:MM:105 E87672
Ms. Kimberly Novak
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, OH 44130
RE: The tariff classification of PCB Handling Equipment from Belgium
Dear Ms. Novak :
In your letters, dated July 12 and September 15, 1999, for ITE Inc., you requested a tariff classification ruling. Additional information, but no sample, was received from Mr. T. Isaacs of ITE via his E-mail to you, dated September 14, 1999, and via his telephone conversation with NIS A. Horowitz of this office on October 14, 1999.
The import is a “printed circuit board handling equipment that moves a PCB into an area where contact is made with a piece of test equipment.” It is “incapable of performing any electrical testing per se”; it “is strictly a PCB handling system, built on top of a standard piece of cabinetry that customers can mount their own equipment into.” The customer’s equipment will send electricity through the PCB’s contacts and determine its performance by measuring and evaluating the output electricity.
The import handles PCBs which are between 80 by 80 millimeters (10 square inches) and 325 by 400 millimeters (1.4 square feet) in size and up to 2.5 kilograms (5.5 pounds) in weight. The transport system consist primarily of a belt that is 600 millimeters (2 feet) wide which has a maximum transport speed of 800 millimeters per second (2.6 feet per second).
As we understand your information, the import has no capability of rejecting on its own any “defective” PCBs, for example, those that do not meet rigorous specifications for shape and size. It only uses tooling pins to ensure that the board has been correctly transported so that it is properly positioned and aligned for the testing to be done by the customer’s equipment.
Although your July 12 letter included 4 pages of information about testing Cell Phones, Mr. Isaacs has clearly indicated that that is only one example of the possible testing systems in which the import will be used. Whether or not the imports will principally be used in the testing of PCBs that are used in telecommunications equipment, there is no indication that they are specially designed for those PCBs as opposed to those used in non-telecommunication equipment.
Its Note 1-g excludes from HTS Chapter 90 “lifting and handling machinery”. Its Note 2-a excludes parts and accessories which are “goods included in any of the headings...of chapter 84...” It has been determined that neither exclusion applies to this import.
The applicable subheading for this item will be 9030.90.8860 , Harmonized Tariff Schedule of the United States (HTS), which provides for “other” parts and accessories of instruments and apparatus for measuring or checking electrical quantities. The general rate of duty will be 1.7 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist James Sheridan at 212-637-7037.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division