Newly Released CBP HQ Rulings for Oct. 2
The Customs Rulings Online Search System (CROSS) was updated on Oct. 6 with the following headquarters ruling (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):
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H341544: Country of Origin of an Analog Integrated Circuit
| Ruling: The country of origin of the analog integrated circuit diode will be either Japan or Taiwan, depending on where the front-end processing occurs. |
| Issue: What is the country of origin of an analog integrated circuit? |
| Item: 3PEAK's analog integrated circuit, which is used for applications within communications, industrial, security monitoring, medical and healthcare, instrumentation, new energy and automotive sectors. |
| Reason: CBP noted that each individual die on the semiconductor wafers includes complete integrated circuit functionality after the completion of extensive and complex front-operations that occur in either Japan or Taiwan. On the other hand, the back-end operations described in 3PEAK's submission, including wafer sawing and trimming, only amount to minor processing of a product whose use and identity will already be established by the extensive front-end operations. These back-end operations do not change the essential character and use of the analog integrated circuit, which were already established as a result of various front-end operations. Accordingly, the analog integrated circuit does not undergo a substantial transformation in China during back-end processing. |
| Ruling Date: Sept. 25, 2024 |