The Court of International Trade has ruled that certain printed circuit board assemblies are properly classified as parts and accessories of automatic data processing machines under HTSUS 8473.30.1180 (duty-free) but do not qualify for any of three exclusions from Section 301 tariffs on imports from China.
The items at issue are PCAs used for cryptocurrency mining that incorporate a graphics processing unit, eight gigabytes of onboard memory, eight megabits of electrically erasable programmable read-only memory, and other electronic components such as capacitors, resistors, and other ancillary components. All of these are encased in a protective aluminum enclosure with connection ports for power and extruding data transmission connectors.
The CIT agreed that these PCAs are classified under HTSUS 8473.30.1180 because they (1) are parts or accessories (because they must be connected to a machine with a central processing unit to function), (2) of ADP machines (i.e., servers that accept new applications), and (3) are solely or principally used for such machines (because they have no independent functionality or usefulness).
The court thus rejected the U.S.’ argument that the PCAs are classified as parts of other electrical machines and apparatus under HTSUS 8543.90.68 (duty-free), which is a residual provision covering machines not specified or included elsewhere.
However, the CIT also ruled that the PCAs do not qualify for (1) either of two exclusions from the China Section 301 tariffs for PCAs with graphics-related function, because they are incapable of rendering images onto computer screens and do not enhance the graphics performance of ADP machines, or (2) a separate exclusion for unfinished logic boards, because at importation they contain all necessary components to function within an ADP and are therefore not unfinished.
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