The tariff classification of Registered Buffers (Registers) from Japan, Taiwan, and Germany

NY K85978 June 3, 2004 CLA-2-85:RR:NC:MM:109 K85978 CATEGORY: Classification TARIFF NO.: 8542.21.8079 Ms. Joyce Ford ECC Specialist Infineon Technologies Richmond 6000 Technology Blvd. Sandston, VA 23150 RE: The tariff classification of Registered Buffers (Registers) from Japan, Taiwan, and Germany Dear Ms. Ford: In your letter dated May 13. 2004, you requested a tariff classification ruling. The merchandise is identified in your letter as Registered Buffers (Registers). Your letter also states that the terms “Register” and “Registered Buffers” are used synonymously in the semiconductor industry to define a memory device designed to store bits of data for short periods of time (nanoseconds). While the data points are stored in the “Register”, a phase lock loop (PLL or differential clock) synchronizes the data signals to avoid overwriting other incoming data signals before routing the data to the final storage location in the memory chip. The “Registered Buffer” has 24 to 48 bits. These Registered Buffers are used on memory modules in servers. Servers are used when multiple users are storing data in the same place. Unbuffered memory modules do not need registered buffers because only one data source has access to write to the memory chips. For example, in a home computer, unbuffered memory modules are used because only one person at a time can be logged on to the home computer. With a server, many different users can all be logged on to the server at the same time. Your letter provided the following example as to how the Registered Buffers work: You can think of bits of data as cars coming into a parking lot from two different entrances. The “registered Buffer” is the line of cars stopped at the entrances of the parking lot by the flagman (flagman = Phase Lock Loop or Differential Clock) that only allows one car from one direction at a time to enter the parking lot to avoid having two cars crash into each other while trying to park in the same parking spot (parking spot = memory chip). The applicable subheading for the Registered Buffers (Registers) will be 8542.21.8079, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electronic integrated circuits and microassemblies; parts thereof: Monolithic integrated circuits: Digital: Other: Other: Silicon: Other, including microprocessors, …Microprocessors having an internal data bus of: 32 bits or more.” The rate of duty will be free. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Linda M. Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division