CLA-2-85:OT:RR:NC:N1:109
Mr. Joseph Kim
Director, Global Trade Compliance
Xilinx, Inc.
2100 Logic Drive
San Jose, CA 95124
RE: The tariff classification of a Xilinx® Kintex™-7 410 from an unspecified country
Dear Mr. Kim:
In your letter dated September 29, 2011, you requested a tariff classification ruling.
The merchandise subject to this ruling is a Xilinx® Kintex™-7 410. The Xilinx® Kintex™-7 410 is part of the family of products of Xilinx® Series 7 FPGAs (Field Programmable Gate Arrays). All model types in the family of products exhibit the same essential features and employ the same procedures in their production.
The Series 7 FPGAs, specifically the Xilinx® Kintex™-7 410, provide a range of features including advanced high-performance FPGA logic based on real 6-input lookup table (LUT) technology configurable as distributed memory, digital signal processor (DSP) slices for limited computational functions, configurable memory, high-performance I/O (input/output) to support DDR3 interfaces up to 1,866 Mb/s, high-speed serial connectivity transceivers to handle up to 28.05 Gb/s, interface for PCI Express®, 12-bit 1MSPS analog-to-digital converters, and support options for commodity memory, encryption, and error. The Xilinx® Series 7 FPGA does not contain all necessary features to become a self-contained end-use device. Instead, it must be placed on a system board of a system that the Xilinx® Series 7 FPGA will function as a part of.
The Xilinx® Kintex™-7 410 consists primarily of three main components, the insulating substrate incorporating passive elements obtained by thin-film technology, a monolithic integrated circuit obtained from semiconductor technology, and discrete components, specifically capacitors and resistors. The monolithic integrated circuit, capacitors and resistors are all mounted on the same insulating substrate upon which the thin-film technology has been formed.
The insulating substrate used to develop the Xilinx® Kintex™-7 410 is an organic build-up type of epoxy-core and ABF-film (Ajinomoto Build-up Film, a dielectric build up), which is drilled, plated, and etched. It is made up of a core layer comprising the core material, a plated through hole (PTH) via (the via is an electrical pathway), a PTH fill material placed within the PTH, and a PTH pad layer placed on the front and back of the core material. Upon the insulating substrate, layers of dielectric material and copper traces are deposited and then etched to create the front Build Up (BU) layer above the insulating substrate and the back BU layer below the insulating substrate, which function as the passive elements. The function of the passive elements, i.e., resistors, inductors, capacitors, and impedance elements, provided by the BU layers, furnish the necessary electric characteristics to enable the Xilinx® Kintex™-7 410 to perform as designed. The ABF-film is repeatedly laminated and via built-up, using thin-film deposition and plating, symmetrically on both sides of the core. The presence of various materials and the positioning of the traces within the BU layers govern the resistance, inductance, capacitance, and impedance that the digital signals experience. Therefore, the design of the insulating substrate and BU dielectric layers with correct thin-film metallization (or plating), lamination, and etching processes are critical in achieving the desired electrical and performance results.
The thin-film metallization used to create copper traces is a method of plating the copper onto dielectric material using the thin-film deposition technique. The resulting copper trace layers are thin films created by thin-film technology. These traces and dielectric material layers form the circuitry that interconnects the digital signals traveling between the silicon die and the system board of which the Xilinx® Kintex™-7 410 will become a part of. These thin-film BU layers are different from standard printed circuit board layers, which are constructed from fiberglass dielectric and laminated copper layers.
A monolithic integrated circuit, an active component, is interconnected to and mounted on the thin-film circuit through microvias between copper layers and through the “bumps” on top of the substrate. Once mounted, the monolithic integrated circuit, the BU layers, and the insulating substrate are combined to all intents and purposes indivisibly.
The Xilinx® Kintex™-7 410 also incorporates discrete passive components, specifically capacitors and resistors, which are fixed onto the substrate and are visible on the packing of this FPGA.
Based on the method of manufacture, the Xilinx® Kintex™-7 410 meets the definition of a hybrid integrated circuit in accordance with Note 8 (b) (ii) to Chapter 85 and is classifiable within heading 8542. The classification of integrated circuits at the subheading level is based on its function. The Xilinx® Kintex™-7 410 is a FPGA. A FPGA is a type of integrated circuit that can be reprogrammed to a desired application or functionality requirement after the manufacturing of the integrated circuit. This feature distinguishes FPGAs from Application Specific Integrated circuits (ASICs), which are custom manufactured for specific design tasks. However, FPGAs can be used to implement any function that an ASIC could perform. As such, the Xilinx® Kintex™-7 410 does not have one specific function.
The applicable subheading for the Xilinx® Kintex™-7 410, which is among the Xilinx® Series 7 FPGA (Field Programmable Gate Array) family of products, will be 8542.39.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electronic integrated circuits: Other." The rate of duty will be free.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
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