Mr. Jay Park
Excel International of N.Y. Corp.
146-27 167th St, Suite 201
Jamaica, NY 11434

RE: The tariff classification of plastic covers and mounts from China.

Dear Mr. Park:

In your letter dated January 28, 2009 for Flow Dental, you requested a tariff classification ruling. Five samples were provided.

The first two samples are a Comfees Sensor Sleeve and an Econo Comfees Sensor Sleeve. They are small, transparent, plastic covers for sensors that are used in dental X-rays. The sensor is placed inside the patient’s mouth, converts the X-rays which strike it into electrical signals, and transmits those signals via an electrical wire to other apparatus. The sensors are thus analogous to the X-ray screens cited in the Heading to HTSUS 9022. The sleeve is designed to protect the sensor and to help protect the patient’s mouth from its edges.

The next two samples are the Safe’n’Sure and Deluxe Safe’n’Sure Phosphor Plate Barrier Envelopes.   A phosphor plate is placed in a barrier envelope and then placed on a film holding device.  The phosphor plates are exposed to x-rays inside the patient’s mouth, removed, and then read by a specialized apparatus.  These envelopes are not accessories to X-ray apparatus, but rather are accessories to photographic plates and films, which are excluded from heading 9022 by Harmonized System Explanatory Note Exclusion (b) to 9022.

The last sample is a Flow X-ray mount. Developed dental x-rays are placed into one of the multiple, transparent pockets of the mount. They remain in the mount for storage and during examination of the x-rays by use of a negatoscope (to shine light through them.)

The applicable subheading for the Sensor Sleeves will be 9022.90.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “other” parts and accessories of apparatus based on the use of X-rays. The rate of duty will be 0.8 percent ad valorem.

The applicable subheading for the phosphor plate barrier envelopes will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the dental X-ray film mounts will be 3926.90.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastic, frames, and mounts for photographic slides. The rate of duty will be 3.8 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 J. Sheridan at 646-733-3012.


Robert B. Swierupski
National Commodity Specialist Division