OT:RR:CTF:VSP H345243 ACH

Mr. Steven B. Zisser
Zisser Customs Law Group
9355 Airway Rd.
San Diego, CA 91107

RE: Applicability of Subheading 9817.00.96, HTSUS; Intermittent Catheters

Dear Mr. Zisser:

This is in response to your request, on behalf of ConvaTec, dated January 31, 2025, for a binding ruling regarding the applicability of subheading 9817.00.96, Harmonized Tariff Schedule of the United States (“HTSUS”), to intermittent catheters. Our ruling is set forth below.

FACTS:

The merchandise addressed in this ruling request are “intermittent catheters,” which are part of ConvaTec’s Continence Care and Critical Care line. ConvaTec’s intermittent catheters are listed under “continence care” on its website. The website states: “{a}t Convatec we create products and services for people with urinary continence issues related to spinal cord injuries, multiple sclerosis, spina bifida and other causes…”1 Only intermittent catheters are at issue in this ruling.

Urinary catheters are medical devices designed to help drain urine from the bladder when a person cannot do so naturally. These flexible tubes are inserted into the bladder through the urethra or, in some cases, through a small surgical opening in the abdomen. They are commonly used for patients experiencing urinary retention, following certain surgeries, or during long-term conditions that affect bladder function.

Proper bladder emptying is critical, as incomplete emptying can lead to complications such as urinary tract infections, overflow urinary incontinence, and permanent damage to the bladder and kidneys.

1 https://www.convatecgroup.com/our-categories/continence-care/ There are two main types of urinary catheters, each suited to different medical needs:

1) Indwelling Catheters (Foley Catheters) (not at issue in this ruling): These catheters are placed in the bladder through the urethra or stomach wall by a medical professional and are often secured by a small balloon inflated inside the bladder. They remain in place for an extended period until the user does not need them. 2) Intermittent Catheters: These catheters are known as single-use catheters. These catheters are inserted into the urethra, past the sphincter muscle and into the bladder. They are used multiple times throughout the day, and they are removed and discarded immediately after use. Intermittent catheters are designed so catheterization can be performed by the patient themselves.

A study published in the Canadian Urological Association Journal found: “Given the benefits of single-use catheters and all the uncertainties with reuse, we believe that repeated use of catheters should not be the preferred method for long-term bladder management.” 2

Intermittent catheters enable individuals with permanent and chronic conditions, such as spinal cord injuries, multiple sclerosis, urinary incontinence, and neurogenic bladder, to manage their bladder function independently. Intermittent catheters are available in a variety of designs and configurations tailored to the user’s needs, preferences, and gender. These variations ensure accessibility and ease of use. For example, ConvaTec states that the self-catheterization capability, gender-specific designs, specialized grips and handling features, and pre-lubricated and compact designs enable patients with physical impairments to independently manage this critical bodily function despite limitations in dexterity, mobility, or cognitive function.

In some cases, intermittent catheters are prescribed for patients recovering from acute urinary retention, urological surgery, or spinal surgery, as they temporarily may be unable to effectively empty their bladder. ConvaTec states that doctors typically recommend their use for a period of at least three to six months; however, there is always a risk of long-term complications that could necessitate the continued or even permanent use of intermittent self-catheterization.

Articles on catheters from both United States and United Kingdom health services provide greater guidance on who typically uses urinary catheters.

Urinary catheters are used to drain the bladder. Your health care provider may recommend that you use a catheter if you have: urinary incontinence (leaking urine or being unable to control when you urinate), urinary retention (being unable to empty your bladder when you need to), surgery on the prostate or genitals, other medical conditions such as multiple sclerosis, spinal cord injury, dementia, or other operations.3

2 https://pmc.ncbi.nlm.nih.gov/articles/PMC6363567/#:~:text=multiple%20catheter%20use.- ,Conclusion,children%20doing%20self%2Dcatheterization). 3 https://medlineplus.gov/ency/article/003981.htm

2 Specific reasons a urinary catheter may be used include: to allow urine to drain if you have an obstruction in the tube that carries urine out of your bladder (urethra). For example: because of scarring or prostate enlargement; to allow you to urinate if you have bladder weakness or nerve damage that affects your ability to pee; to drain your bladder during childbirth if you have an epidural anesthetic; to drain your bladder before, during, or after some types of surgery; to deliver medicine directly into the bladder, such as during chemotherapy for bladder cancer; as a last resort treatment for urinary incontinence when other types of treatment have been unsuccessful. Depending on the type of catheter you have and why it’s being used, the catheter may be removed after a few minutes, hours or days, or it may be needed for the long term.4

ConvaTec provided a physician’s letter stating that 85% of intermittent catheter users have long-term conditions requiring use for more than three years, including multiple sclerosis (28%), spinal cord injuries (18%), diabetes-related bladder dysfunction (8%), diagnosed neurogenic bladder (5%), and other chronic urological conditions (26%). An additional 8% of users have conditions requiring intermediate-term use (1 to 3 years), while only about 7% use these devices for short-term management (less than 1 year), with post-operative recovery representing just 1% of users.

ISSUE:

Whether the intermittent catheters imported by ConvaTec are eligible for duty-free treatment under subheading 9817.00.96, HTSUS.

LAW AND ANALYSIS:

1. The Intermittent Catheters are Eligible for Duty-free Treatment under Subheading 9817.00.96, HTSUS.

The Nairobi Protocol to the Agreement on the Importation of Educational, Scientific and Cultural Materials of 1982, Pub. L. No. 97-446, 96 Stat. 2329, 2346 (1983) established the duty- free treatment for certain articles for the handicapped. Presidential Proclamation 5978 and Section 1121 of the Omnibus Trade and Competitiveness Act of 1988, provided for the implementation of the Nairobi Protocol into subheadings 9817.00.92, 9817.00.94, and 9817.00.96, HTSUS.

Subheading 9817.00.96, HTSUS, covers: “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing articles . . . Other.” CBP must evaluate “for whose, if anyone’s, use and benefit is the article specially designed.” Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (C.I.T. 2017), aff’d, 899 F.3d 1308 (Fed. Cir. 2018). In Sigvaris, the CIT explained that:

4 https://www.nhs.uk/conditions/urinary-catheters/

3 The term “specially” is synonymous with “particularly,” which is defined as “to an extent greater than in other cases or towards others.” Webster’s Third New International Dictionary 1647, 2186 (unabr. 2002). The dictionary definition for “designed” is something that is “done, performed, or made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” Webster’s Third New International Dictionary 612 (unabr. 2002).

In Sigvaris, the court used the Plaintiff’s own advertising materials to determine whether the products were specially designed for the use of persons who are physically handicapped.

Subheading 9817.00.96, HTSUS, excludes: “(i) articles for acute or transient disability; (ii) spectacles, dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS. Thus, classification under subheading 9817.00.96, HTSUS, depends on whether the article is “specially designed or adapted for the use or benefit of the blind or physically and mentally handicapped persons,” and whether it falls within any of the enumerated exclusions under U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS.

The term “blind or other physically or mentally handicapped persons” includes “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS. While the HTSUS does not establish a clear definition of “substantial limitation,” in Sigvaris, 227 F. Supp 3d at 1335, the CIT explained that “[t]he inclusion of the word ‘substantially’ denotes that the limitation must be ‘considerable in amount’ or ‘to a large degree.’”

To determine whether the intermittent catheters are “specially designed” for the use or benefit of a class of persons to an extent greater than for others, CBP must examine the following five factors adopted by the CAFC in Sigvaris, 899 F.3d at 1314-15: (1) physical properties of the article itself (e.g., whether the article is easily distinguishable in design, form and use from articles useful to non-handicapped persons); (2) presence of any characteristics that create a substantial probability of use by the chronically handicapped, so that the article is easily distinguishable from articles useful to the general public and any use thereof by the general public is so improbable that it would be fugitive; (3) importation by manufacturers or distributors recognized or proven to be involved in this class or kind of articles for the handicapped; (4) sale in specialty stores that serve handicapped individuals; and (5) indication at the time of importation that the article is for the handicapped. See also T.D. 92-77 (26 Cust. B. 240 (1992)).

As to whether those who use catheters are handicapped, in HQ 085175, dated October 20, 1989, Customs stated, “we see no absolute correlation between being incontinent and being mentally or physically handicapped. It is quite possible to be incontinent and healthy in every other way. Incontinence in and of itself is not a physical handicap…” However, as stated in HQ H328390, dated January 25, 2024, Customs determined in multiple other rulings that a person suffering from chronic incontinence is physically handicapped. See HQ 960056, dated January 30, 1997, which cites to two rulings that held certain products to be specially designed for the

4 handicapped within subheading 9817.00.96, HTSUS; HQ 085691, dated April 18, 1990, (which considered washable, breathable diapers used by men and women in hospitals); and HQ 557529, dated March 8, 1994 (which considered an institutional adult diaper designed to manage serious, chronic incontinence problems).

CBP is satisfied that incontinence necessitating the use of catheterization constitutes an impairment which substantially limits one or more major life activities. Though CBP previously stated that there is no absolute correlation between incontinence and disability, it has since issued multiple rulings holding that incontinence may be considered a handicap. Further, incontinence is not the primary disability affecting many people who use intermittent catheters. The materials provided by ConvaTec show that these devices are often used by those with multiple sclerosis, spina bifida, spinal cord injuries, and other disabilities. Therefore, we are satisfied that these intermittent catheters are used by physically or mentally handicapped persons.

There is evidence that the intermittent catheters at issue are specially designed for use by the physically handicapped. Regarding the first two Sigvaris factors, it is highly unlikely that members of the public would use these intermittent catheters unless one of the aforementioned disabilities listed in the description so required. Further, the catheters enable those with physical disabilities to void with ease, whether the user self-catheterizes, or with the assistance of a personal care assistant/health professional, because these catheters have specialized grips and handling features designed specifically for users with limited manual dexterity and pre-lubricated and compact designs to accommodate mobility limitations.

For the third through fifth factors, ConvaTec Group’s website states, “Convatec is a global medical products and technologies group focused on solutions for the management of chronic conditions.”5 ConvaTec sells two types of intermittent catheters—Cure Medical and GentleCath. The Cure Medical website includes lists of catheters “by condition,” including multiple sclerosis, pelvic organ prolapse, prostate cancer, spina bifida, spinal cord injury, and transverse myelitis.”6 The website includes pictures of many people in wheelchairs and testimonials from disabled individuals. Further, the GentleCath “get started” pamphlets provided by ConvaTec also show pictures of men and women in wheelchairs, which indicates that they are the intended audience.

Therefore, CBP holds that these intermittent catheters are specially designed for the use or benefit of handicapped persons. However, Subheading 9817.00.96, HTSUS, excludes articles for acute or transient disability, even if those articles are specially designed for the use or benefit of handicapped persons.

In HQ 556532, dated June 18, 1992, Customs held that canes were predominantly used by permanently or chronically handicapped individuals, even though individuals with acute disabilities such as sprained ankles could use them. On the other hand, Customs stated that crutches were predominantly used by individuals with acute or transient disabilities, even though they may be used by individuals with chronic or permanent disabilities. Therefore, CBP must

5 https://www.convatecgroup.com/ 6 https://curemedical.com/

5 determine whether these intermittent catheters are used predominantly by individuals with acute or transient disabilities or by individuals with chronic or permanent disabilities.

Here, though there is a wide variety of disabilities and conditions necessitating the use of catheters, the materials given to CBP show that the predominant use of the intermittent catheters at issue is to help handicapped people perform the everyday task of relieving themselves. Again, ConvaTec Group’s website states, “Convatec is a global medical products and technologies group focused on solutions for the management of chronic conditions.” 7 ConvaTec sells two types of intermittent catheters—Cure Medical and GentleCath. The Cure Medical website includes lists of catheters “by condition,” including multiple sclerosis, pelvic organ prolapse, prostate cancer, spina bifida, spinal cord injury, and transverse myelitis.” 8 The website includes pictures of many people in wheelchairs and testimonials from disabled individuals.

Though urinary catheters are used temporarily, the evidence presented indicates that is not the predominant use of the intermittent catheters at issue here. ConvaTec is clearly marketing its products to those who have permanent and chronic conditions. The photographs on its website and catheter pamphlets feature users in wheelchairs and testimonials from those with permanent disabilities. Further, ConvaTec provided documentation stating that 85% of intermittent catheter users have long-term conditions requiring use for more than three years. Therefore, we believe the predominant use of these catheters is for the treatment of chronic conditions.

CBP has also looked to the temporary nature of an article itself to determine whether it is used by individuals with chronic or acute disabilities. In HQ 563008, dated May 20, 2004, aff’d, HQ 563530, dated September 27, 2006, CBP held that disposable incontinent care products that were not durable or reusable or designed for long-term use over a long period of time were not eligible for duty-free treatment under subheading 9817.00.96, HTSUS. In HQ 085094, dated May 10, 1990, Customs stated that “an individual with acute or transitory incontinence would not be likely to purchase reusable products, such as those at issue, based on cost alone. Such an individual could easily meet their need for much less with disposable products.”

However, in HQ H328390, dated January 25, 2024, Customs noted that, in some instances, non-disposable goods may be less effective. Further, in HQ 562869, dated December 23, 2003, Customs held that disposable insulin pump infusion sets were eligible for duty-free treatment under subheading 9817.00.96, HTSUS. In HQ H966555, dated September 9, 2003, Customs affirmed decisions holding that disposable ostomy bags were eligible for duty-free treatment under subheading 9817.00.96, HTSUS.

Though Customs has shown a preference for goods that are reusable in determining whether the goods are for permanent or temporary conditions, there is evidence that doctors recommend intermittent catheters even to those who use catheters consistently over a long period of time because intermittent catheters cause fewer complications and improve the quality of life of users. Single-use catheters are also recommended because they are more sanitary. Therefore,

7 Convatecgroup.com 8 https://curemedical.com/

6 the fact that the intermittent catheters are single-use does not necessarily show that their predominant use is by those with acute or transient disabilities.

Subheading 9817.00.96, HTSUS, also excludes therapeutic and diagnostic articles. In Richards Medical Co. v. U.S., 13 C.I.T. 519 (1989), “the Court {found} that the term ‘therapeutic’ distinguishes articles, which are used to heal the condition causing a handicap, from those duty-free articles which are designed to compensate for, or adapt to, the handicapped condition.”9 The court determined that a prosthetic hip was not a therapeutic article. Further, in Travenol Lab. V. U.S., 17 C.I.T. 69 (1993), the court determined that, because kidney dialysis does not restore the kidney function of a person with renal failure, it was not a therapeutic procedure. Like the prosthetic hip and dialysis articles, the intermittent catheters help manage but do not cure an underlying condition. Incontinence is an issue while individuals use the catheter, and still is an issue if users stop using the catheter. Therefore, we believe the catheters do not treat but simply help users manage the underlying condition causing the incontinence.

HOLDING:

The intermittent catheters at issue are eligible for duty-free treatment under subheading 9817.00.96, HTSUS, as articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the internet at https://hts.usitc.gov.

Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect. The application of a ruling letter by a Customs Service field office to the transaction to which it is purported to relate is subject to the verification of the facts incorporated in the ruling letter, a comparison of the transaction described therein to the actual transaction, and the satisfaction of any conditions on which the ruling was based.”

A copy of this ruling letter should be attached to the entry documents filed at the time the goods are entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the CBP officer handling the transaction.

Sincerely,

Monika R. Brenner, Chief
Valuation and Special Programs Branch

9
This case defined “therapeutic” under a predecessor heading to subheading 9817.00.96, HTSUS.

7