CLA-2-39:OT:RR:NC:N4:415
Laurence Hart
Fridababy, LLC
82 Northeast 26th Street
Miami, FL 33137
RE: The tariff classification of a nasal aspirator from Sweden.
Dear Mr. Hart:
In your letter dated April 16, 2025, you requested a tariff classification ruling.
Images were provided in lieu of a sample.
The product under consideration is described as the “frida baby® NoseFrida® SnotSucker.” It is a plastic
nasal aspirator that allows a parent/caregiver to remove excess mucus from an infant’s nose. The device
consists of a large tube with a tapered end, a disposable filter, a filter cap, a tube, and a mouthpiece. It is
manually operated by suction created from the user sucking into the mouthpiece, with the mucus going into
the large tube and being prevented from traveling to the mouthpiece by the filter.
In your request, you suggested that this product should be classified under subheading 8414.10.0000,
Harmonized Tariff Schedule of the United States (HTSUS), as an air or vacuum pump. We note that this
item does not have any mechanical features and therefore would be excluded from chapter 84 and more
specifically heading 8414. Alternatively, you propose subheading 3926.90.2100, HTSUS, which provides
for “[i]ce bags; douche bags, enema bags, hot water bottles, and fittings therefor; invalid and similar nursing
cushions; dress shields; pessaries; prophylactics; bulbs for syringes; syringes (other than hypodermic
syringes) and fittings therefor, not in part of glass or metal.” This aspirator is not one of the specific articles
listed in the subheading language and must be classified elsewhere.
As the “frida baby® NoseFrida® SnotSucker” would be considered an article of plastic, and as it is not more
specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, which
provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther:
[o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs. ? All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ?Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to
subheading 3926.90.9989, HTSUS, listed above.
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/current.
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 Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division