CIT Relies on Merriam-Webster to Classify Crypto Mining Cards as Parts and Accessories

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Jan. 29, 2026
By: Pietro N. Bianchi

In Atlas Power, LLC v. United States, Slip Op. 26-04 (Jan. 27, 2026), the Court of International Trade ruled in part for Atlas and in part for the U.S. when it held that NVIDIA’s Crypto Mining Processor 170HX printed circuit assemblies are properly classified in 8473.30.1180 as “parts and accessories” of automatic data processing (“ADP”) machines but did not qualify for any Section 301 exclusions.

The court relied on dictionary definitions of the terms “part” and “accessory” when holding for Atlas that the crypto mining cards should be classified in 8473.30.1180. Those familiar with the HTSUS know that “parts” and “accessories” are not defined by the tariff despite being scattered abundantly throughout. The court’s decision to rely on dictionary definitions is notable because case law attempting to provide a legal framework for these terms exists, indicating a potential break from that convention.

The Court determined “part” is a constituent member of another apparatus, while an “accessory” is not essential in itself but adds to the effectiveness of something else. The court held that because the crypto mining cards cannot work independently and must be connected to an ADP in order to function, they are parts and accessories of ADPs. Because the court ultimately held that the cards are classified in 8473.30.1180, they are excluded from the Government's proposed classification in 8543.90.6800, which is a residual provision for parts “not specified or included elsewhere.”

The court again turned to lexicographical sources to determine whether Section 301 exclusions were applicable. The court determined that the common industry meaning of “graphics” was the “computer’s display system” or the “creation and manipulation of picture images” and held that because the cards lacked “the capability to render images on a computer screen,” they did not qualify as “graphics card” excluded from Section 301 in Notes 20(ttt)(iii)(108)–(109), Ch. 99, HTSUS:

• “Printed circuit assemblies for rendering images onto computer screens (“graphics processing modules”);” and
• “Printed circuit assemblies to enhance the graphics performance of automatic data processing (ADP) machines.”

Lastly, the court determined that the crypto mining cards did not qualify for the exclusion for “unfinished logic boards” in Notes 20(ttt)(iii)(110), Ch. 99, HTSUS. The court found that the cards had the “essential character” of a finished logic board because they “contained all of the necessary hardware and firmware components, particularly a VBIOS installed onto the EEPROM, necessary for functionality with an ADP machine” at the time of importation.

Navigating the tariff has become increasingly difficult with the continuous and abrupt modifications of the past year. If you have questions, please contact an attorney at Barnes Richardson, & Colburn LLP