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NY L86237




September 1, 2005

CLA-2-90:RR:NC:MM:114 L86237

CATEGORY: CLASSIFICATION

TARIFF NO.: 9031.49.90

Ms. Karen Cecca-Capillo
Exel Global Logistics Inc.
150 Eastern Avenue
Chelsea, MA 02150

RE: The tariff classification of Automated Optical Inspection System from France

Dear Ms. Cecca-Capillo:

In your letter dated August 3, 2005, on behalf of Vision Inspection Technology, Inc., you requested a tariff classification ruling.

The Automated Optical Inspection System, model Vi-3K2, is used to inspect printed circuit boards. The system inspects the solder paste, the component’s X, Y and Theta deviation, the presence and absence of components, the component polarity, and the solder joints and bridges. The system consists of a monochrome digital camera (1600 by 1200 pixels), programmable lighting, a molded granite frame, a gantry with X-axis linear motor with magnets fixed directly onto the granite and Y-axis linear motor with dual rails on beam, a conveyor, and AVision software. The Vi-3K2 can be integrated at multiple locations in the PCB assembly line and a repair station can be linked to the Vi-3K2 so that errors detected by the Vi-3K2 during inspection can be downloaded to the repair station.

The applicable subheading for the Vi-3K2 automated optical inspection system will be 9031.49.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for the measuring and checking instruments appliances and machines, not specified or included elsewhere in this chapter, other. The rate of duty will be 3.5 percent ad valorem.

We cannot issue a ruling on the classification of the software without additional information. Is the software imbedded on the device or is it imported as a separate entity? If separate, please specify the medium on which the software is mounted and the software’s inherent characteristics (data, instructions, sound, interactivity, etc.). If imported as a separate entity, please specify the device with which the software will be used.

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 Barbara Kiefer at 646-733-3019.

Sincerely,

Robert B. Swierupski
Director,

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