CLA-2-85:OT:RR:NC:N1:112
Ruth N. Girmscheid
President
International Customs Services Inc.
N64 W24801 Main Street
Suite 121
Sussex, WI 53089
RE: The tariff classification of UV-C automatic room disinfection system from an undisclosed country of origin.
Dear Ms. Girmscheid:
In your letter dated April 28, 2014, you requested a tariff classification ruling on behalf of your client, Preventamed Technologies, Inc.
The merchandise in question is known as the Surfacide® UV-C Surface Disinfection Solution. This device utilizes high intensity ultraviolet (UV) light emitting towers (HeliosTM) that direct and concentrate the UV light by slowly rotating while emitting UV light in order to disinfect hard surface areas.
You have suggested classification for the Surfacide®, which is an automatic UV-C room disinfection system, under subheading 9018.20.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for instruments and appliances used in medical, surgical, dental or veterinary sciences, which are ultraviolet or infrared ray apparatus or parts and accessories thereof. The Surfacide® performs the same function as the items in rulings N022250 and N025969 which classified a UV-C light sanitizer under heading 8543, HTSUS. As such, this device is also able to operate in any environment and is not relegated to operating in the medical, surgical, dental or veterinary fields. Subheading 9018.20.0080, HTSUS, is not applicable to the Surfacide®.
The applicable subheading for the Surfacide® UV-C Surface Disinfection system will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions…: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6%.
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/.
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 Karl Moosbrugger at [email protected].
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division