CLA-2-84:OT:RR:NC:N1:104
Regina Girsh
KNS Industries
1005 Virginia Dr. Ft. Washington, PA 19034
RE: The tariff classification of dispensing machines from Taiwan
Dear Ms. Girsh:
In your letter dated September 9, 2024, you requested a tariff classification ruling.
At issue are five series of robotic dispensing machines for surface mount technology (SMT) dispensing operations. The dispensing machines perform various bonding, sealing, and coating applications in connection with the assembly of semiconductors, LEDs, and electronics. They are principally used to apply epoxies, adhesives, solder paste, and other fluid materials in connection with semiconductor device and integrated circuit assembly or packaging, including dam and fill, LED encapsulation, Chip Scale Package (CSP), Chip on Board (COB) encapsulation, and ball grid array (BGA) for integrated circuits. The packaging process shields the semiconductor die from physical damage, moisture, and other environmental conditions.
All the subject dispensing machines are equipped with fine-tuned valves and nozzles to ensure accurate fluid material deposition. To control of movement of the subject machines' fluid dispenser applicators and ensure the accuracy of dispensation, the units utilize a three-dimensional XYZ coordinate system, representing three axes of motion: horizontal (X), vertical (Y), and depth or height (Z).
The GLE/GLLM Robot series is designed for a range of applications in several industries, including SMT glue dot dispensing, module encapsulation, potting, COB encapsulation, component underfill, LCD display, solder paste jetting, camera lens bonding, camera module epoxy sealing, smartphone glass/metal case bonding, dam and fill, and conformal coating. However, you indicate that the principal use of the GLE and GLLM machines is in semiconductor device/LED packaging applications such as underfill and solder paste dispensing. These machines measure (mm) 900 x 1932 x 1920 (W x D x H) and weigh 1300 kg.
The SL/SSL Series micro dispensing robotic platforms are specifically designed for semiconductor micro fluid packaging applications for SiP, narrow gap filling, fine line silver paste dispensing, and micro underfill. The SL/SSL Series are designed to accept up to a 12-inch semiconductor wafer. The SL Series measure (mm) 900 x 1850 x 1829 (W x D x H) and weigh 1740 kg. The SSL Series measure (mm) 700 x 1995 x 1756 (W x D x H) and weigh 1050 kg.
The XLS Series are robotic dispensing machines for mini/micro-LED packaging applications. The packaging process includes the use of high viscosity optical glue to separate the RGB chips and filling the space (dam) separating the chips with glue. The XLS also supports other semiconductor packaging applications. These machines measure (mm) 1844 x 2859 x 2335 (W x D x H) and weigh 2000 kg.
The Model SSD is a dispensing machine designed for lead frame LED encapsulation. The SSD measures (mm) 1256 x 850 x 2338 (W x D x H) and weighs 500 kg.
The A Series Desktop Robots, are small-scale dispensing machines, mainly used to produce small quantities as part of the pre-production and semiconductor package testing process in R&D operations. Applications include display panel dispensing, underfill, encapsulation, dam and fill, and silver epoxy & solder paste dispensing. While the use of these machines may vary depending upon the specific R&D applications within a lab setting, the information provided suggests their use is associated principally with semiconductor device/LED or integrated circuit assembly. These machines measure (mm) 870 x 920 x 808 (W x D x H) and weigh 140 kg.
The dispensing machines will be imported with dispensing software and post-dispensing automated visual inspection systems (AOI). The software is used to control and manage the dispensing of fluid materials, with features such as remote teaching, motion control, CAD file input, 3D profile printing, automatic dispensing weight measurement and calibration, and AOI.
Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS), Statistical Note 1(d), indicates that assembly equipment for semiconductor and integrated circuit assembly machines include dicing, die and wire bonding, as well as packaging equipment used to encapsulate or package a semiconductor device. Additionally, the Explanatory Notes to Heading 8486, Section (D) Machines and Apparatus Specified in Note 11(c) to Chapter 84, describe machines and apparatus solely or principally of a kind used for assembling semiconductor devices or integrated circuits as including encapsulation equipment such as presses for making the plastic casings for chips by pressing plastic material around the chips.
While the subject dispenser machines are used in a range of industries, the information provided indicates that they are generally optimized for, and principally used in, the semiconductor industry to encapsulate and package semiconductor devices or integrated circuits. Accordingly, we find the subject dispensers to be machines of a kind of falling within HTSUS Chapter 84, Note 11(c), covering assembly and packaging machines.
The applicable subheading for the GLE/GLLM Robot Series, A Series Desktop Robots, SL/SSL Series, XLS Series, and the Model SSD, imported together with their software, will be 8486.40.0020, which provides for Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in note 11(C) to [Chapter 84]; parts and accessories: Machines and apparatus specified in note 11(C) to [Chapter 84]: For assembling semiconductor devices or electronic 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/.
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 Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division