CLA-2-90:RR:NC:N1:105 M86519

Ms. Eleanore Kelly-Kobayashi
Rode & Qualey
55 West 39th Street
New York, NY 10018

RE: The tariff classification of Tubular Metal Needles from Brazil

Dear Kelly-Kobayashi:

In your letter dated September 8, 2006, for Becton Dickinson and Company, you requested a tariff classification ruling. A sample was submitted.

You state: “The cannula, which is the subject of this ruling request, (Product nos. 31481, 31873, 31874 and 31875) is a hollow metal tube which after importation is attached to a plastic hub. The samples enclosed are in two sizes: .852 inches long and 1.34 inches long. The cannula is used in blood collection sets and similar products.”

The samples are just the thin, hollow metal tubes, sharpened at one end. From a review of the WWW, similar items are routinely called needles. Per NIS J. Sheridan’s telephone call to you on September 22, 2006, the four product numbers are for identical products.

You proposed classification in HTSUS 9018.39.0050. However, in that telephone call, you agreed that HTSUS 9018.32.0000 applied.

The applicable subheading for the 31481, 31783, 31784 and 31875 will be 9018.32.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Syringes, needles, catheters, cannulae and the like; parts and accessories thereof – Tubular metal needles… The 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

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 J. Sheridan at 646-733-3012.


Robert B. Swierupski
National Commodity
Specialist Division