CLA-2-90:OT:RR:NC:N1:135
Ms. Wanda Chin
Berlin Packaging
525 West Monroe Street 14th Floor
Chicago, IL 60661
RE: The tariff classification of certain components of an anesthesia medical device applicator from China
Dear Ms. Chin:
In your letter dated February 1, 2018, you requested a tariff classification ruling. A sample received will be returned. Additional information was submitted via email dated February 9, 2018.
Three products are identified in your letter. A handle, tube bottle, and insert head are said to be plastic components of an anesthesia medical device applicator. These components along with a plastic foam applicator, which is not part of this ruling request, form a disposable anesthesia medical device applicator. The completed anesthesia applicator is said to be used predominately in the process of anesthetizing a patient for a surgical or exploratory procedure. The handle component is a semi-tubular shaped plastic holder with a twist-on head used to connect to the insert head component. Inside the handle component, it is designed to house the 26 ml tube bottle component, which is uniquely configured to fix in the handle. The insert head component is an inclining tube shaped article with a rounded triangle bottom used to connect the plastic foam applicator. At the top of the insert head, it has a fixed insert to connect to the handle component.
You propose two shipping scenarios. One is that all three components will be imported individually and separately. The other scenario is that the tube bottle component will be inserted into the handle component and shipped together as an assembly, but the insert head component will be shipped individually.
The applicable subheading for the three components, when shipped in the condition as described in scenario one, will be 9018.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: … Other: Anesthetic instruments and parts and accessories thereof.” The general rate of duty will be free.
The applicable subheading for the tube bottle and handle assembly, and the insert head component, when shipped in the condition as described in scenario two, will be 9018.90.3000, HTSUS, which provides for “Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: … Other: Anesthetic instruments and parts and accessories thereof.” The general 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 https://hts.usitc.gov/current.
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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division