CLA-2-84:OT:RR:NC:N1:104
TARIFF NOS.: 8479.89.9599; 9903.85.08
Lynn Prochazka
Satisloh North America, Inc.
N106W13131 Bradley Way, Suite 200
Germantown, WI 53022
RE: The tariff classification of an ophthalmic lens cleaning system from France
Dear Ms. Prochazka:
In your letter dated March 24, 2025, you requested a tariff classification ruling.
The Satisloh SCL Hydra-Brush-4 is a fully automated, soft brush cleaning system for cleaning the front and
back sides of ophthalmic lenses. This machine is intended for use in high-production ophthalmic lens labs. It
will be used after cutting the prescription into the lens and polishing the lens surface. The Hydra-Brush-4
removes polish residue, ink, tape, glue, and fingerprints, leaving the lenses clean and dry and ready for
inspection. The cleaning process involves four stages: (1) brush cleaning with a rotating soft brush and
detergent; (2) rinsing with municipal water; (3) rinsing with deionized water; and (4) drying with compressed
air. The Hydra-Brush-4 measures 125 (W) x 68 (D) x 91 (H) inches and weighs 2,778 lbs.
The Hydra-Brush-4 employs a chainless lens tray transfer system which ensures each lens is returned to its
original tray, helping to prevent cross-contamination between cleaning stages. The machine also includes an
automatic loading and unloading system that fits standard conveyor heights, six lens holders, and a vibration
unit to align the lenses precisely during cleaning. Additionally, the machine has an integrated refill pump to
automatically supply detergent, plus an integrated deionization device to provide a constant supply of DI
water.
The applicable subheading for the SCL Hydra-Brush-4 cleaning system will be 8479.89.9599, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for Machines and mechanical appliances
having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines
and mechanical appliances: Other: Other: Other. The general rate of duty will be 2.5 percent ad valorem.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 25 percent are reflected in
Chapter 99, headings 9903.85.04 and 9903.85.07. Products provided by heading 9903.85.08 will be subject
to a duty of 25 percent upon the value of the aluminum content.? At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.85.08, in addition to subheading
8479.89.9599, HTSUS.?Derivative aluminum articles processed in another country from aluminum articles
that were smelted and cast in the United States, provided for in heading 9903.85.09, are not subject to the
additional ad valorem duties.
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 Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division