Sylvia Bertolani
CEVA International
8670 Younger Creek Drive
Sacramento, CA 95828

RE: The tariff classification of the Flowkeeper from China

Dear Ms. Bertolani:

In your letter dated March 17, 2016, you requested a tariff classification ruling on behalf of your client, DK Electronics LLC.

The items in question are referred to as the Flowkeepers (Part # EP-201) and the Flowkeeper’s gel pad refills.

The Flowkeepers (Part # EP-201) is an electric muscle stimulator. It consists of an electronic nerve/muscle stimulator in the form of a printed circuit board assembly (PCBA), on/off switch and battery within a common housing. It connects to a polyethylene electcially conductive pad. The Flowkeepers measures 140.6mm in length, 67.14mm in width, and 10.5mm in height.

In use the Flowkeepers would be attached to the calf area of the users leg. Once activated the unit emits an electrical current, or pulse through electrodes contained within the conductive pad which causes muscle/nerve stimulation.

The applicable subheading for the Flowkeeper (Part # EP-201) 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.

The applicable subheading for the Flowkeeper’s gel pad refills (when imported sepertaely) will be 8543.90.8885, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Other: Other: Other.” The rate of duty will be 2.6%.

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


Deborah C. Marinucci
Acting Director
National Commodity Specialist Division