CLA-2-90:OT:RR:NC:N3:135
Mr. Kevin Bruning
CONMED, Inc.
11311 Concept Blvd.
Largo, FL 33773
RE: The tariff classification of an insufflation management system from Germany
Dear Mr. Bruning:
In your letter dated July 15, 2022, you requested a tariff classification ruling. Additional information was provided by email on July 18 and July 20, 2022.
The product under consideration is the CONMED AirSeal® iFS System, which is a 3-in-1 insufflation management system providing stable pneumoperitoneum, constant smoke evacuation, and valve-free access to the abdominal cavity. The system is intended for use in diagnostic and/or therapeutic endoscopic procedures to distend a cavity by filling it with medical grade carbon dioxide to create and maintain a gas-sealed obstruction-free path of entry for endoscopic instruments, and to evacuate surgical smoke. It consists of three basic components: the iFS unit itself, the AirSeal Access Ports (composed of a cannula and an obturator), and three distinct filtered tube sets (one for each mode of operation). The iFS unit is a software-driven device intended for insufflation of a surgical cavity. The front of the iFS unit contains an ON/OFF switch, a touch screen display, a receptacle for the AirSeal and Smoke Evacuation Modes, a lever for locking a tube set in place, and an insufflation tube connection for the Standard Insufflation Mode. The rear of the device includes a gas connector port, an AC electrical connection, a grounding connection, a USB data connection, etc. The device is equipped with a ventilation system with air intake located at the bottom of the device. The iFS unit is capable of operating in three different insufflation operating modes – AirSeal Mode, Smoke Evacuation Mode, and Standard Insufflation Mode. In AirSeal Mode, the iFS unit can be used with a Tri-Lumen Filtered Tube Set and an AirSeal Access Port to provide stable pneumoperitoneum, constant smoke evacuation, and high flow insufflation. In Smoke Evacuation Mode, the IFS unit can be used with a Bifurcated Dual-Lumen Filtered Tube Set and two conventional trocars to provide both high-flow insufflation and continuous smoke evacuation. In Standard Insufflation Mode, the IFS unit provides high-flow insufflation and can be used with a Single Lumen Filtered Tube Set and conventional trocars. You request classification of the entire AirSeal® iFS System.
The applicable subheading for the entire AirSeal® iFS System will be 9018.90.7580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: [o]ther instruments and appliances and parts and accessories thereof: [o]ther: [e]lectro-medical instruments and appliances and parts and accessories thereof: [o]ther: [o]ther:[o]ther.” The general 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 https://hts.usitc.gov/current.
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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division