CLA-2-73:OT:RR:NC:N1:164
Brian Smith
STERIS Corporation
5960 Heisley Rd.
Mentor, OH 44060
RE: The tariff classification of instrument stringers from Germany
Dear Mr. Smith:
In your letter dated April 17, 2025, you requested a tariff classification ruling on instrument stringers from
Germany. Technical information was submitted with your request.
The items under consideration are described as stainless steel (304 18/8 grade) surgical instrument stringers
of various sizes. Instrument stringers are used to keep hinged surgical instruments open during cleaning and
sterilization processes. Based on the submitted information, the main component of the subject instrument
stringers is a U-shaped frame of a single circular stainless steel profile. During use, the finger rings of hinged
surgical instruments are slid onto the parallel sides of the frame. The parallel sides of the frame are spaced at
a distance that keeps the finger rings, and thus the instrument, in an open position to allow for thorough
cleaning and sterilization. If a tray is used, the instrument stringers also keep ring-handled instruments
organized.
The style of the subject instrument stringers is “ball and socket.” Ball and socket stringers feature a hinged
stainless steel extension arm at the end of one side of the frame with a round protuberance on the end. To
close the open side of the U-shaped frame, the hinged extension arm is moved into the perpendicular (closed)
position and the round protuberance snaps into a corresponding socket on the opposite side of the frame. This
feature prevents the surgical instruments from sliding out during use. The subject model numbers and lengths
are as follows: RIS12504 (4 inches), RIS12506 (6 inches), RIS12508 (8 inches), RIS12510 (10 inches),
RIS12512 (12 inches). All subject models are 2.5 inches wide.
The applicable subheading for the instrument stringers will be 7326.90.8688, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for Other articles of iron or steel: Other: Other: Other: Other:
Other. The general rate of duty will be 2.9 percent ad valorem.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e. 9903.81.90, in addition to subheading 7326.90.8688,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under ?privileged foreign
status? before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, HTSUS.
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. Your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 7326.90.8688, 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/.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division