Mr. Jerome Schraub
Mi-Tu Instructional Services Inc.
P.O. Box 346, Alden Manor Branch
Floral Park, NY 11003
RE: The tariff classification of hypodermic needles from the
Dear Mr. Schraub:
In your letter dated July 18, 1991, you requested a tariff
The sample needles you furnished are tubular with a beveled
point and measure 1 3/4 inches in length and 0.134 inch in outer
diameter. They are used to inject animals.
The applicable subheading for the hypodermic needles will be
9018.32.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for Instruments and appliances used in
medical, surgical, dental or veterinary sciences... tubular metal
needles. The general most-favored-nation rate of duty is 6.4
percent. However, since the needles will be imported from the
Soviet Union, the column 2 duty rate of 55 percent will apply to
Regarding the marking of the merchandise, the regulations
require that every article of foreign origin (or its container)
imported into the U.S. shall be marked in a conspicuous place as
legibly, indelibly, and permanently as the nature of the article
(or container) will permit, in such manner as to indicate to an
ultimate purchaser in the U.S. the English name of the country of
origin of the article.
We cannot issue a marking ruling since you have not
indicated the type of marking you plan to use. You may wish to
discuss the matter with the Import Specialist at the port where
the merchandise will be imported or apply for a ruling on a
specified form of marking.
The hypodermic needles are subject to Food and Drug
Administration regulation. A completed FDA Form 701 should be
attached to the entry documents for each imported shipment. The
Food and Drug Administration should be consulted for any
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport