CLA-2-90:RR:NC:MM:105 G89529

Mr. Neil R. Trenchard
Siemens Shared Services, LLC
186 Wood Avenue South
Iselin, NJ 08830

RE: The tariff classification of a Head Array Coil from Germany

Dear Mr. Trenchard:

In your letter dated April 11, 2001, you requested a tariff classification ruling.

You state that the Head Array Coil is specially designed for use as and used solely as an element of the Magnetom Harmony Magnetic Resonance Imaging Unit. Although you do not so state, your first two paragraphs describing the unit are almost entirely a word for word repetition of the Harmonized System subheading Explanatory Note for Harmonized Tariff Schedule (HTS) subheading 9018.13. Assuming that description does apply to the unit, we agree that if the entire unit were imported, it would be classified in HTS subheading 9018.13.0000. Per your description and parts list, the import is a combination of special receiving coils, integrated pre-amplifiers, mirrors, and an Integrated Panoramic Array. The Integrated Panoramic Array “allows the user to scan simultaneously with up to eight coils.” The import is integrated into the tabletop used in the Magnetic Resonance Imaging (MRI) procedure and remains on the table. We agree that the import is better described as a part of a MRI, rather than as being covered by any of the headings in HTS chapters 84, 85, or 90 listed in Legal Note 2-a to chapter 90.

The applicable subheading for this item will be 9018.19.9560, Harmonized Tariff Schedule of the United States (HTS), which provides for “other” parts and accessories of electro-diagnostic apparatus. The general rate of duty will be free.

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 James Sheridan at 212-637-7037.

Sincerely,


Robert B. Swierupski
Director,
National Commodity
Specialist Division