RE: The tariff classification and eligibility of the United States-Mexico-Canada Agreement of automated optical inspection systems from Canada

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364058 August 27, 2026 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.49.9000 Zixing Wang DaoAI Robotics Inc. 555 W Hastings Street #1200 Vancouver, BC V6B 4N6 Canada RE: The tariff classification and eligibility of the United States-Mexico-Canada Agreement of automated optical inspection systems from Canada Dear Mr. Wang: In your letter dated August 5, 2026, you inquire whether automated optical inspection systems are eligible for duty free treatment under the United States-Mexico-Canada Agreement (USMCA). You also request a classification ruling. Descriptive literature was provided for our review. The first item under consideration is described as the DaoAI P1, which is an offline two-dimensional automated optical inspection (AOI) system engineered for in-process and final quality assessment of populated printed circuit board assemblies (PCBAs). Featuring an optical resolution of 15 micrometers, the system utilizes a 5-megapixel industrial digital camera equipped with a dual telecentric optical lens and a multi-zone programmable RGB light source to capture high-precision images. These components are mounted on a motorized X-Y stage and managed by an Intel H610-based industrial computer with a discrete GPU, which runs proprietary AI machine-vision software to analyze the boards. The P1 identifies a comprehensive range of component defects—including missing, misoriented, offset, or damaged parts, as well as foreign material and adhesive overflow—and detects various solder issues such as bridges, cold joints, and insufficient or excess solder. By providing an automated accept/reject determination for each component and solder joint, this machine-vision PCBA inspection equipment ensures rigorous quality control in electronics manufacturing. The second item under consideration is described as the DaoAI P2 automated optical inspection system, which is an offline two-dimensional AOI system within the DaoAI P-Series, designed for the in-process and final quality assessment of populated PCBAs. Functionally identical to the P1 model, the P2 utilizes the same motorized X-Y stage, Intel H610-based industrial computer, proprietary AI machine-vision software, and multi-zone programmable RGB lighting configuration. The primary distinction is the system’s enhanced
optical resolution of 10 micrometers, achieved through a higher-resolution industrial digital camera. Like the P1, the P2 performs comprehensive analysis to detect component defects—such as missing, misoriented, or damaged parts—and solder irregularities, providing automated accept/reject determinations to ensure precision in electronics manufacturing. The DaoAI P1 and P2 systems are manufactured in Canada using components imported from China in three separate shipments. The first shipment contains the industrial camera (heading 8525), the second includes the Intel H610 industrial computer with its discrete GPU and RAM (headings 8471 and 8473), and the third comprises the mechanical and motion platform, including the frame, panels, X-Y motion components, lens, lighting, monitor, and cabling (headings 7326, 7616, 8482, 8501, 9002, and 9405). Upon receipt, the assembly process begins with the mounting and alignment of the camera, dual telecentric lens, and multi-zone RGB lighting. The industrial computer is then integrated and configured, followed by the synchronization of the camera, motion, lighting, and computer communication systems. Finally, the proprietary software is deployed, inspection parameters are established, and defect recognition is trained and validated using reference boards. The production process concludes with the verification of optical alignment and calibration, followed by rigorous quality control and acceptance testing prior to final shipment. The applicable subheading for the DaoAI P1 and DaoAI P2 automated optical inspection systems will be 9031.49.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other optical instruments and appliances: Other: Other.” The general rate of duty will be free. USMCA The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (GN) 11 of the Harmonized Tariff Schedule of the United States (HTSUS) implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)). In your letter, you explain the final assembly of the product occurs in Canada using components from China. Since the subject automated optical inspection systems contain non-originating materials, they are not considered goods wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN 11(b)(iii) and GN 11(o). The applicable tariff shift rule in GN 11(o) for products classifiable under subheading 9031.49, HTSUS, requires a change to subheading 9031.49 from any other heading.
Each individual item that encompasses the final DaoAI P1 and DaoAI P2 automated optical inspection systems are classified outside of subheading 9031. As a result, each component used to create the fully functional automated optical inspection systems undergo the appropriate change and the tariff shift requirement is met. Accordingly, the DaoAI P1 and DaoAI P2 automated optical inspection systems are eligible for preferential tariff treatment under the USMCA. 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 Jason Christie at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division