The tariff classification of dicing blades from China.

N342165 September 12, 2024 CLA-2-68:OT:RR:NC:N1:128 CATEGORY: Classification TARIFF NO.:  6804.21.0090, 9903.88.03 Ms. Regina Girsh KNS Industries 1005 Virginia DriveFort Washington, PA 19034 RE:  The tariff classification of dicing blades from China. Dear Ms. Girsh: In your letter dated August 20, 2024, you requested a tariff classification ruling. The merchandise under consideration is referred to as dicing blades, item numbers S1635-Q500-COL Blade, Q1025-Q500-COL Hub Blade, J1535-K200-ATK Semitec Nova Dicing Blades, S1235-Q5SH-ATK Semitec Standard Dicing Blade, and F1435 Standard Dicing Blade.  From the information you provided, all five dicing blades measure 55.6 millimeters in diameter by 4.6 millimeters in thickness at their widest points, and consist of diamond agglomerated with nickel which has been affixed to a continuous rim aluminum alloy plate.  The blades are used in semiconductor dicer machines to cut semiconductor wafers or IC chips.  You state that the cutting is achieved solely by the abrasive material.   The applicable subheading for the dicing blades, item numbers S1635-Q500-COL Blade, Q1025-Q500-COL Hub Blade, J1535-K200-ATK Semitec Nova Dicing Blades, S1235-Q5SH-ATK Semitec Standard Dicing Blade, and F1435 Standard Dicing Blade, will be 6804.21.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Millstones, grindstones, grinding wheels and the like, without frameworks, for grinding, sharpening, polishing, trueing or cutting….Other millstones, grindstones, grinding wheels and the like:  Of agglomerated synthetic or natural diamond:  Other.”  The general rate of duty will be Free. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 6804.21.0090, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty.  At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 6804.21.0090, HTSUS, listed above. The merchandise in question may be subject to antidumping duties (AD) for diamond sawblades from China (A-570-900).  Written decisions regarding the scope of AD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce (ITA) and are separate from tariff classification and origin rulings issued by Customs and Border Protection (CBP).  General information regarding the ITA and AD/CVD can be found at https://www.trade.gov/us-antidumping-and-countervailing-duties.  The ITA’s “Guide on How to File for an Antidumping/Countervailing Duty Scope Ruling Request” is available at https://enforcement.trade.gov/scope/Request-Scope-Ruling.pdf. 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 Nicole Sullivan at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division