The tariff classification of a pre-install cable set from the Netherlands

N362917
July 28, 2026
CLA-2-85:OT:RR:NC:N2:220
CATEGORY: Classification
TARIFF NO.: 8544.70.0000
Edward Juliano, Jr. Edward F. Juliano, Jr. - Attorney at Law 303 Wyman Street, Suite 300 Waltham, MA 02451 RE: The tariff classification of a pre-install cable set from the Netherlands Dear Mr. Juliano: In your letter dated July 7, 2026, you requested a tariff classification ruling on behalf of your client, ASML US, LLC. The merchandise under consideration is a pre-install cable set referred to as the NXE 3800E Pre-Install Cable Set. The pre-install cable set is further described as a cable set consisting of optical fiber, electrical, and communications cables. The set includes approximately 158 cables or cable bundles and 50 other brackets or connectors which comprise the complete assembly. In use, the pre-install cable set is a component of the NXE 3880E Extreme Ultraviolet semiconductor lithography system. In your request, you describe two scenarios in which the pre-install cable set may be imported. In scenario 1, all items in the pre-install cable set are imported together in a single shipment. In scenario 2, the pre-install cable set is split into two shipments, shipment “A” and shipment “B”. In both scenarios, the cables, brackets, and other components are packed together and will be shipped to a semiconductor manufacturing plant in the United States for incorporation into the NXE 3800E semiconductor lithography system. The General Rules of Interpretation (GRIs) of the Harmonized Tariff System of the United States (HTSUS), when taken in numerical order, set forth the official guidance for classifying merchandise as it enters the US. GRI 1 states, in part, that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3, HTSUS. GRI 3(a) states, in part, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods, those headings are to be regarded as equally specific, even if one heading gives a more precise description of the good. Goods classifiable under GRI 3(b) are classified as if

they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. GRI 3(c) provides that when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in numerical order among those which equally merit consideration. In our opinion, the pre-install cable set meets the definition of a composite good because it contains electrical, fiber optic, and communication cables. In this case, our opinion is that none of these elements provide the essential character of the finished cable set as all are critical to the cable set’s end use within the NXE 3880E Extreme Ultraviolet semiconductor lithography system. After a review of all competing subheadings, we have determined that the fiber optic cables occur last in numerical order. For both import scenarios, the applicable subheading for the NXE 3800E Pre-Install Cable Set will be 8544.70.0000, HTSUS, which provides for “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Optical Fiber cables.” The general rate of duty will be free. The duties cited above are current as of this ruling’s issuance. 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Gary Chaffee at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division