CLA-2-90:OT:RR:NC:N1:105
Ms. Joan Studeny
GHY USA Inc.
572 South Fifth Street
Pembina, ND 58271
RE: The tariff classification and country of origin of MRI’s and various related items exported from Canada
Dear Ms. Studeny:
In your undated letter for Imris Inc., you requested a tariff classification and country of origin ruling. No sample was provided.
The complete IMRIS Neuro II-SE Intra-operative Magnetic Resonance Imaging System is similar to the items described in the Harmonized System Explanatory Note for Subheading 9018.13.
We agree that the applicable subheading for the IMRIS Neuro II-SE Intra-operative Magnetic Resonance Imaging System will be 9018.13.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Magnetic resonance imaging apparatus. The rate of duty will be Free.
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 World Wide Web at http://www.usitc.gov/tata/hts/.
You have also requested a country of origin ruling for the complete MRI and five shipments of related items as well as the classification of those shipments. You indicate that the five shipments may not be eligible for entry as a unit under Customs Regulation 141.58 since they may not be shipped into the US within the required time frame of each other.
Regarding those issues, we are returning your request for a ruling, and any related samples, exhibits, etc. We need additional information in order to issue a ruling. Please submit the information described below:
You provide two pages of component numbers that are apparently included in the shipments, but you provide only an “Object Description” of a few words for each. Provide for each a detailed description of what it does and how it does it. Which shipments will each be in? If they are elements of a subassembly, what does the subassembly do and how does it do it? What is the approximate cost of each component? What, if anything, makes each component “identifiable” as a part or accessory of an MRI of 9018.13? When a country of origin is shown, is the item entirely a product of that country? If not, what are the elements from another country? When the country of origin is shown as a question mark, explain the countries which were considered and which elements were supplied by each.
Regarding the division into shipments, for example in regard to shipment 5, explain which of the listed components are the “Additional requirements out of Canada that may be required for final installation,” assuming that they are all listed. Similarly for the other 4 shipments.
Also include a statement as to whether classification advice has been sought from a Customs officer; and if so, from whom, and what advice was rendered, if any.
Please limit your ruling request to a maximum of 5 items of the same class or kind. This may require separate requests for, at minimum, separate shipments.
If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section.
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 J. Sheridan at 646-733-3012.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division