Mr. J.R. Landa
Unit International, Inc.
644 Cesery Blvd. Suite 200
Jacksonville, FL 32211

RE: The tariff classification of a pediatric urine collector from China

Dear Mr. Landa:

In your letter dated January 12, 2007, on behalf of PSS World Medical, you requested a tariff classification ruling.

The sample submitted with your request is a pediatric urine collector. The collector consists of a plastic bag with printed measurements. The opening is surrounded by a foam ring on the interior and surrounded by adhesive on the exterior, protected by a peel-off paper backing. The collector is available in both sterile and non-sterile versions.

You suggest classification in subheading 9018.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other instruments and appliances used in medical, surgical, dental or veterinary sciences and parts and accessories thereof. You cite New York Ruling E83373, which, we note, is dated June 28, 1999. However, that ruling concerned urine drainage bags which, unlike your item, could be strapped to the patient’s leg and which were connected to an indwelling catheter, which would have been inserted by medical personnel. The pediatric urine collector submitted with your request may be used at home or at a lab to collect urine for laboratory analysis. There is no need for involvement by any medical personnel.

This office also notes that, per item 5 of the Classification Decisions of September, 2005, the Harmonized System Committee of the World Customs Organization determined that even a sterile graduated urinary drainage bag that was “fitted with a tubing, catheter adapter, valve/port for taking urine samples and a hook for attachment to a bed or mobile holder” was not classified in Harmonized System heading 9018. It is clear that your item is further removed from the descriptions in the Harmonized System Explanatory Notes to 9018 than the one in item 5, above.

The applicable subheading for the pediatric urine collector will be 3926.90.9810, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other…laboratory ware. The rate of duty will be 5.3 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 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 Joan Mazzola at 646-733-3023.


Robert B. Swierupski
National Commodity
Specialist Division