CLA-2-85:RR:NC:MM:109 L86818

Mr. Sam Olivio
Corporate Materials Manager
NGK Spark Plugs (USA) Inc.
One NGK Drive
Sissonville, WV 25320

RE: The tariff classification of the Application Specific Integrated Circuit (UEGO ASIC) from Japan

Dear Mr. Olivio:

In your letter dated July 29, 2005, you requested a tariff classification ruling.

The subject of this letter is an Application Specific Integrated Circuit hereafter identified as an ASIC that is used in conjunction with the NTK Universal Exhaust Gas Oxygen (UEGO) sensor. The ASIC is commonly referred to as the UEGO ASIC.

The UEGO ASIC is an application specific integrated circuit that consists of active elements on a single silicon wafer. It does not contain any memory. The UEGO ASIC is placed between the UEGO sensor and the Central Processing Unit (CPU) in an automobile’s engine control unit (ECU). The UEGO ASIC receives signals from the UEGO sensor in the form of small voltage currents that vary according to the A/F ratio of the exhaust gas. The UEGO ASIC processes the signal from the UEGO sensor and transmits an analyzed signal of the A/F ratio of the emission gas that allows the CPU to process the signal. The UEGO ASIC also measures the element temperature of the UEGO sensor. The UEGO ASIC sends a signal to the CPU which changes the control heater voltage, if necessary, to achieve the proper temperature of the sensor head. A sample of the merchandise was submitted for classification to this office as part of this ruling request.

You suggested in your ruling request letter that the subject merchandise be classified under Harmonized Tariff Schedule of The United States (HTSUS) 8542.21.8089, which provides for “Electronic integrated circuits and microassemblies; parts thereof: Monolithic integrated circuits: Digital: Other: Other: Silicon: Other, including …application specific integrated circuits (ASIC)…:Other: Other, which is free of duty. A telephone conversation with Ms. Debbie Blaylock of NGK Spark Plug USA Inc. on September 14, 2005, established the fact that the UEGO ASIC is only an analog device.

The applicable subheading for the UEGO ASIC will be 8542.29.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for Monolithic integrated circuits: Other: Other: Other.” The rate of duty will be free.

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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division