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Issues: Whether the imported AMOLED display assembly used in the manufacture of cellular mobile phones is classifiable under Tariff Item 85249220 as a flat panel display module, or under Tariff Item 85177990 as parts of mobile phones.
Analysis: The classification had to be determined first by the terms of the competing headings and the relevant Chapter and Section Notes. Heading 8524 specifically covers flat panel display modules, and Note 7 to Chapter 85 permits such modules to include elements necessary for receiving video signals and allocating those signals to pixels. The exclusion in Note 7 applies only where the module is equipped with components for converting video signals or otherwise assumes the character of goods of another heading. The impugned goods were found to be display assemblies whose primary function remained display, with the driver IC performing display-related signal handling such as timing, pixel control, and conversion necessary for OLED operation. They did not contain an application processor, scaler IC, decoder IC, modem, or any independent transmission or processing capability. The applicant also failed to produce contemporaneous technical material showing that the imported goods contained video-converting components of the kind contemplated by the exclusion clause. Since the goods were themselves specifically covered by heading 8524, Section XVI Note 2(a) required classification in that heading, and there was no scope to resort to parts classification under heading 8517 merely because the goods were intended for use in smartphones.
Conclusion: The imported display assembly is classifiable under Tariff Item 85249220 and not under Tariff Item 85177990.
Ratio Decidendi: Where a product is specifically covered by a tariff heading as a flat panel display module, the existence of a driver IC performing display-related functions does not, without proof of true video-converting components, take it out of that heading; specific classification prevails over a residual parts entry, and end use alone cannot control classification.