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NY A88431




October 31, 1996

CLA-2-84:RR:NC:1:103 A88431

CATEGORY: CLASSIFICATION

TARIFF NO.: 8479.89.9598

Mr. Raymond Tsui
Great World Customs Service
1305 Grandview Drive
South San Francisco, CA 94080

RE: The tariff classification of electronic component placement machines from Japan

Dear Mr. Tsui:

In your letter dated October 4, 1996 on behalf of Simpu Research Corp. DBA Uniq Technology you requested a tariff classification ruling.

With your inquiry you submitted descriptive literature on the model KE730 and the model KE740 pick and place machines. These machines are used to assemble electronic components such as resistors, capacitors, transistors, and electronic integrated circuits onto bare printed circuit boards using a high speed, high precision placement system. The components are picked from containers or reels mounted on the machine and positioned and assembled onto the PCB in accordance with programmed instructions. The placement system incorporates a laser beam which determines positional and angular deviation to ensure accurate placement. The placement heads are moved to the proper position by means of an X-Y mechanism featuring a servo motor drive and a linear encoder control system. The model KE730 chip placer can continuously assemble electronic components in .28 of a second, while the model KE740 general purpose placer is capable of placing components in .34 of a second. Both machines can assemble some 100 different types of components.

In your letter you asked whether these machines could be classified in subheading 8479.89.85, Harmonized Tariff Schedule of the United States (HTS), a duty-free provision encompassing, among other things, machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other: other: ...machines for production and assembly of diodes, transistors and similar semiconductor devices and electronic integrated circuits.... However, subheading 8479.89.85 is limited to machines which actually produce or assemble diodes, transistors and similar semiconductor devices and electronic integrated circuits themselves. The models KE730 and KE740 do not produce or assemble these items, but rather place diodes, transistors, etc. which have already been produced or assembled onto PCB's. Accordingly, these machines do not fall within the language of this subheading and thus cannot be classified therein.

The applicable subheading for the KE730 and KE740 electronic component placement machines will be 8479.89.9598, HTS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other: other: other: other. The rate of duty will be 3.2 percent ad valorem.

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 Alan Horowitz at 212-466-5494.

Sincerely,

Roger J. Silvestri
Director

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