CIT Rules "Chip Placers" are More Than Machines Used to Lift, Handle, Load or Unload Material
In Fuji America Corp. v. U.S., the Court of International Trade ruled that an imported machine identified as a "chip placer" and a part identified as a "feeder" were both properly classified under HTS heading 8479.
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Chip placers are machines that are used to place various electronic components such as resistors, capacitors and circuits onto blank printed circuit boards. The chip placer at issue is composed of several discrete units, including a loading system, a component placement system, and a parts inspection system. The feeder is both a motor and power source designed to supply the electronic components to the chip placer.
Fuji claimed the chip placer should be classified as other lifting, handling, loading or unloading machinery under heading 8428, and the feeder should be classified under 8431 as parts of heading 8428 machines.
Fuji stated that the chip placer is an "industrial robot" whose primary function is lifting and handling computer components, operations explicitly included in the language of heading 8428.
Customs argued that both the chip placer and feeder should be classified under heading 8479, and more specifically, under HTS 8479.89, which provides for "Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter." Further, Customs stated that the chip placers do not transport, position or store materials.
The CIT stated that the chip placer was a high-speed assembly machine performing more than just lifting, handling, loading and unloading operations. It further ruled that its primary function was mounting electronic components onto the printed circuit assembly, with the primary function of the feeder being to supply such parts to the chip placer.
Thus, the CIT ruled classification of both imported items was in heading 8479, with the chip placer in HTS 8479.89 and the feeder under HTS 8479.90 as parts of those machines.
CIT Slip Op. 06-116 (dated 07/26/06) available at: http://www.cit.uscourts.gov/slip_op/Slip_op06/06-116.pdf