CLA-2-82:OT:RR:NC:N1:118
Sean Doran
Logfret Inc.
301 Penhorn Ave., Unit 1
Secaucus, NJ 07094
RE: The tariff classification of Derma Roller from China
Dear Mr. Doran:
In your letter dated March 5, 2025, on behalf of your client, Cosfibel Inc., you requested a tariff classification
ruling.
The merchandise under consideration is identified as a Derma Roller, item number KA1127C. It is a
hand-operated tool with an aluminum handle and small blunt stainless-steel needles mounted on a roller. The
tool measures 151.5 mm in overall length and the head of the tool measures 29.74 mm in width. The user
rolls the tool over areas of the scalp in order to create tiny holes in the skin. You have stated that the tool is
meant to be used in conjunction with shampoo and a hair serum to help stimulate and gently exfoliate the
scalp. The item is a personal care tool and not meant to be used by medical professionals.
The applicable subheading for the Derma Roller, item KA1127C, will be 8205.51.3060 Harmonized Tariff
Schedule of the United States (HTSUS), which provides for handtools (including glass cutters) not elsewhere
specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than
accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or
pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass
cutters) and parts thereof: household tools, and parts thereof: of iron or steel: other (including parts): other
(including parts). The general rate of duty will be 3.7% ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8205.51.3060, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 8205.51.3060, HTSUS, listed above.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8205.51.3060, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Anthony Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division