Martina B. Williams
Greater Concepts by Design
1803 Springside Court
Plainfield, Il 60586

RE: The tariff classification of an electric muscle and transcutaneous nerve stimulation system from China

Dear Ms. Williams:

In your letter dated June 28, 2011, you requested a tariff classification ruling.

The merchandise concerned is an electric muscle stimulation (EMS) and transcutaneous electrical nerve stimulation (T.E.N.S.) system, model # ETG 255. This system, which is packaged ready for retail sale, includes a dual channel electronic nerve stimulator, eight adhesive electrode pads, two connecting cables, four AAA batteries, a belt clip and instruction manual. The electronic nerve stimulator measures 109 mm x 68 mm x 31 mm and incorporates a liquid crystal display screen, various selection/operation buttons and two electrical sockets located on the top of the device. There are numerous operational settings/functions available to the user, for example there is a timer function, fifteen programs for muscle stimulation (EMS) and three programs for nerve stimulation (TENS). The electrode pads have connectors/plugs that extend from their side. The two electrical cables incorporate electrical connectors on each end. The electrical cables are used to connect the electronic nerve stimulator to the electrode pads.

In use, the electrode pads are placed directly on the user’s skin, over the desired region of the body. The electrode pads are connected to the stimulator unit using the included cables. Then the unit is turned on and the program and length of time is selected. Based on the program selected, this device will generate electrical impulses that are used to stimulate either muscle nerves (EMS) or sensory nerves (TENS).

The applicable subheading for the electric muscle stimulation (EMS) and transcutaneous electrical nerve stimulation (T.E.N.S.) system, model # ETG 255 will be 8543.70.8500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: For electrical nerve stimulation.” 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 Steven Pollichino at (646) 733-3008.


Robert B. Swierupski
National Commodity Specialist Division