CLA-2-84:OT:RR:NC:N1:104
Elizabeth Gadley
Comau LLC
21000 Telegraph Road
Southfield, MI 48033
RE: The tariff classification of a mechanical support device from Italy.
Dear Ms. Gadley:
In your letter dated June 11, 2019, you requested a tariff classification ruling.
The Comau MATE Exoskeleton (muscular aiding tech exoskeleton), is a wearable ergonomically designed support structure composed of (1) a garment interface (made of plastic and textile) that is in direct contact with the user’s body, (2) a mechanical shoulder chain that facilitates the free movement of the user, such as sliding and rotational joints, and (3) two torque generator boxes which are capable of storing and transforming the potential mechanical energy of a series of pretensioned springs in order to create a variable assistive torque for each arm.
The MATE is worn on the upper body and utilizes a passive torque spring box mechanism that provides a support force under each upper arm. Each torque box has seven adjustments ranging from 0 degrees to 120 degrees and requires no electric power to function. They assist the shoulder muscles by replicating dynamic movements of the shoulders such as lifting heaving objects, reaching overhead, or performing other physically taxing activities and helps prevent the joints from rotating beyond the safe range of motion.
Typical applications of the MATE are screwing with raised arms; assembly operations performed with raised arms; and underbody operations in the automotive sector. The MATE can only be used by people in a state of both good physical and psychological health and is not considered a medical device.
The applicable subheading for the Comau MATE Exoskeleton will be 8479.89.9499, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other”. The rate of duty will be 2.5 percent ad valorem.
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 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 Denise Hopkins at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division