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N168335: The tariff classification of replacement mandrels from China
Ruling Date: Jun 22, 2011
N168335
June 22, 2011
CLA-2-84:OT:RR:NC:1:104
CATEGORY: Classification
TARIFF NO.: 8486.90.0000
Mr. Steven B. Zisser
9355 Airway Road
Suite 1
San Diego, CA 92154
RE: The tariff classification of replacement mandrels from China
Dear Mr. Zisser:
In your letter dated May 21, 2011, on behalf of your client ITW Rippey, you requested a tariff classification ruling. A representative physical sample of the mandrels in question was submitted for examination. As per a telephone conversation and email dated June 14, 2011 between this office and Mr. Juan Moreno of your office, the submitted sample of the replacement mandrel (Part # S-929091) need not be returned to your office.
The replacement mandrels are designed for exclusive use in a semiconductor manufacturing machines. The mandrels are hollow, flow-through cores which are available in various designs, shapes and sizes ranging from 15 mm to 356 mm. These cylindrical components are made of a synthetic polymer, unreinforced, semi-crystalline thermoplastic polymer, and polyethylene terephthalate. The primary purpose of the mandrels is to act as supports for specially designed Polyvinyl Acetal (PVA) Brushes which are not included at the time of importation. The PVA Brushes are used in post-CMP brush scrubbing operations in which unwanted film and particulates are removed from the surfaces of semiconductor wafers by a brush scrubbing action. Cleaning solutions are delivered to the brushes through the perforations located in the mandrels. Generally, an original OEM mandrel is used with each new/replacement PVA Brush. However, some semiconductor manufacturing customers regularly require replacement mandrels. Others require replacement mandrels pre-mounted with a replacement PVA Brush. In your letter, you state that replacement mandrels are never imported with a PVA Brush. Some PVA Brushes are pre-mounted onto a replacement mandrel after the importation into the United States.
In your letter, you propose that the replacement mandrels be classified in subheading 8483.10.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other transmission shafts and cranks. As per the National Import Specialist for this subheading, while the shaft may receive torque from the machine drive, it appears to function as a part of the brush assembly, not as a transmission shaft of 8483. The shaft is hollow and features perforations which allow fluid to be fed through the brush.
The applicable subheading for the replacement mandrels will be 8486.90.0000, HTSUS, 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 9 (C) to this chapter; parts and accessories: Parts and accessories. 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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division
June 22, 2011
CLA-2-84:OT:RR:NC:1:104
CATEGORY: Classification
TARIFF NO.: 8486.90.0000
Mr. Steven B. Zisser
9355 Airway Road
Suite 1
San Diego, CA 92154
RE: The tariff classification of replacement mandrels from China
Dear Mr. Zisser:
In your letter dated May 21, 2011, on behalf of your client ITW Rippey, you requested a tariff classification ruling. A representative physical sample of the mandrels in question was submitted for examination. As per a telephone conversation and email dated June 14, 2011 between this office and Mr. Juan Moreno of your office, the submitted sample of the replacement mandrel (Part # S-929091) need not be returned to your office.
The replacement mandrels are designed for exclusive use in a semiconductor manufacturing machines. The mandrels are hollow, flow-through cores which are available in various designs, shapes and sizes ranging from 15 mm to 356 mm. These cylindrical components are made of a synthetic polymer, unreinforced, semi-crystalline thermoplastic polymer, and polyethylene terephthalate. The primary purpose of the mandrels is to act as supports for specially designed Polyvinyl Acetal (PVA) Brushes which are not included at the time of importation. The PVA Brushes are used in post-CMP brush scrubbing operations in which unwanted film and particulates are removed from the surfaces of semiconductor wafers by a brush scrubbing action. Cleaning solutions are delivered to the brushes through the perforations located in the mandrels. Generally, an original OEM mandrel is used with each new/replacement PVA Brush. However, some semiconductor manufacturing customers regularly require replacement mandrels. Others require replacement mandrels pre-mounted with a replacement PVA Brush. In your letter, you state that replacement mandrels are never imported with a PVA Brush. Some PVA Brushes are pre-mounted onto a replacement mandrel after the importation into the United States.
In your letter, you propose that the replacement mandrels be classified in subheading 8483.10.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other transmission shafts and cranks. As per the National Import Specialist for this subheading, while the shaft may receive torque from the machine drive, it appears to function as a part of the brush assembly, not as a transmission shaft of 8483. The shaft is hollow and features perforations which allow fluid to be fed through the brush.
The applicable subheading for the replacement mandrels will be 8486.90.0000, HTSUS, 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 9 (C) to this chapter; parts and accessories: Parts and accessories. 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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division