CLA-2-90:OT:RR:NC:N1:105
Andrea Lucaroni EDA Industries S.p.a. Via dell’elettronica snc Cittaducale 02015 Italy
RE: The tariff classification of semiconductor test equipment from Italy
Dear Ms. Lucaroni:
In your letter dated January 8, 2024, on behalf of your client, ROHM Semiconductor U.S.A. LLC, you requested a tariff classification ruling.
The first item under consideration is described as the ETNA System, which is test equipment specifically designed for qualification and burn-in trials on a wide range of semiconductor devices. The system is based on three main platforms. The first is the test platform, which includes the electronics needed to stimulate and monitor the devices under test (DUTs). The second is the thermal platform, which includes the climatic chambers to perform the trials at different temperatures. The third is the software platform, which includes the operating software needed to implement the test programs to which the DUTs are subjected, collect the test results, and analyze them. The voltage and current measurements are displayed on the graphical user interface in real time as the trial progresses. Additionally, the results of the measuring and monitoring step are logged into a dedicated report accessible at the end of the trials. The system is primarily designed for testing chips dedicated to electric cars. The ETNA System has up to twenty-four test slots, measures 225cm high by 230cm wide by 210cm long and weighs 3100kg. The system features two additional racks, which allows for additional storage of samples to be tested, that each measure 225cm high by 105cm wide by 90cm long and weigh 700kg.
The second item under consideration is described as the ETNA Engineering Test Station (ETS). This item includes only a few test slots to perform preliminary tests at the work bench, and does not include any thermal platform because the tests are performed at room temperature. The ETNA ETS will be used for qualification of semiconductor devices according to the various applicable standards (e.g., Jedec standard, Automotive Electronics Council (AEC)). The ETNA System has up to three test slots, measures 150cm high by 90cm wide by 200cm high (including the support table) and weighs 250kg.
In operation, the user would place the semiconductor chips to be tested into the ETNA system. After the test flow is initiated, the user would monitor the results on the graphical user interface. The measurements for each chip are displayed and the user can determine whether the chip has failed due to the test and stress parameters. The parameters can be configured for each device and failed chips are automatically sorted into a separate bin. When the test is completed, the user will take the chips that have passed the tests and store them for future use. New chips would then be added to the ETNA system and the process is repeated with a new batch. The ETNA ETS operates in a substantially similar manner, even using the same software. However, the ETNA ETS is smaller, so it performs fewer tests and can be run at room temperature.
Accordingly, the applicable subheading for the ETNA System and ETNA ETS will be 9030.82.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Oscilloscopes, spectrum analyzers and other instruments and apparatus for measuring or checking electrical quantities, excluding meters of heading 9028; instruments and apparatus for measuring or detecting alpha, beta, gamma, X-ray, cosmic or other ionizing radiations; parts and accessories thereof: Other instruments and apparatus: For measuring or checking semiconductor wafers or devices (including integrated circuits).” The general 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 at https://hts.usitc.gov/current.
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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division