The tariff classification of serial input/output (SIO) board assembly from Mexico

N296274 May 8, 2018 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification TARIFF NO.: 8538.90.3000 Tracey Pruett Benchmark Electronics 4807 Bradford Dr. Huntsville AL 35805 RE: The tariff classification of serial input/output (SIO) board assembly from Mexico Dear Ms. Pruett: In your letter dated April 19, 2018 you requested a tariff classification ruling. The merchandise under consideration is referred to as the SIO board, PN HAA34-3480C, which is described as a printed circuit board assembly (PCBA) that interfaces between the Computer Numerical Control (CNC) main control board and other machines, such as tool changers, chip conveyors, coolant pumps, and the discreet and analog input signals. In your submission you state the SIO board also interfaces with external sensors and converts their signals for use with the CNC main control board. In your request you suggest the subject SIO board assembly is correctly classified in 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS). We disagree as the SIO assembly is used within a CNC system to process control signals and execute certain control functions (turn pump on/off, etc.). As the primary function appears to be that of control processing, this PCBA would be beyond the scope of heading 8517. As an alternative, you suggest the SIO board is classifiable in subheading 8538.90.3000, HTSUS. As the SIO PCBA is a PCBA that is principally used with a CNC machine of heading 8537, we agree with your suggestion. The applicable subheading for the SIO board, PN HAA34-3480C will be 8538.90.3000 HTSUS, which provides for “Parts suitable for use solely or principally with the apparatus of heading 8535, 8536 or 8537: Other: Printed circuit assemblies: Other”. The rate of duty will be 3.5 percent ad valorem. 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 https://hts.usitc.gov/current. 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 Karl Moosbrugger at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division