CLA-2-83:OT:RR:NC:N5:121
Desiree Ferguson
Tente Casters Inc
2266 Southpark Drive
Hebron, KY 41048
RE: The tariff classification of casters and wheel assemblies from France
Dear Ms. Ferguson:
In your letter dated April 22, 2025, you requested a tariff classification ruling.
The first item, listed as 5944 UAP 125 R26-28S45 HTC9003/WR7015, is a swivel caster that will be used
solely on a Spectra Optia Apsheresis System. The housing and the center of the wheel are made of
polyamide, the wheel tread is made of polyurethane, and the mounting stem is made of steel. The wheel
diameter is 125 mm, and the wheel width is 15 mm.
The second item, listed as 5947 UAP 125 P30-13 HTC9003 WR7015, is a plastic caster that will be used
solely on a Spectra Optia Apsheresis System. Per your correspondence, this wheel assembly lacks a metal
stem.
The third item, listed as 5940 UAP 125 P30-13 NP 7001 HTC 7001 WR7015, 5947 UAP 125 P30-13
HTC7001 KICK3000/WR7015, and 594C UAP 125 P30-13 HTC7001 KICK3000/6032 WR7015, are plastic
casters that will be used solely on a medical bassinet for babies to sleep in while in the hospital after birth.
Per your correspondence, these wheel assemblies lack metal stems.
The fourth item, listed as 5947 XSC 125 R05-22X40 HT9002 CKICKWR9011, is a swivel caster that will be
used solely on an INOmax DSIR system. The housing and the center of the wheel are made of polyamide, the
wheel tread is made of polyurethane, and the mounting stem is made of steel. The wheel diameter is 125 mm,
and the wheel width is 20 mm.
The fifth item, listed as 5947 UAP 125 P30-13 HT9002KICKWR9011, is a plastic caster that is used solely
on a Cori Surgical System. Per your correspondence, this wheel assembly lacks a metal stem.
In your letter, you propose classification in heading 9402, Harmonized Tariff Schedule of the United States
(HTSUS), as parts of medical or surgical furniture. However, not all of the systems or devices, such as Cori
Surgical System and Spectra Optia Apsheresis Systems, into which the casters are incorporated, are medical
or surgical furniture. These systems or devices are classified in Chapter 90. Note 1(f) to Chapter 90 and Note
1(d) to Chapter 94 exclude parts of general use, as defined in note 2 to Section XV, of base metal (Section
XV) or similar goods of plastics (chapter 39). In this case, the subject casters fit the description of casters in
the tariff and are considered parts of general use. See Note 2(c) to Section XV. As such, they are excluded
from classification in Chapter 90 or Chapter 94.
We find these products similar to the ones described in New York ruling N245110, dated August 28, 2013,
and will classify them in the same manner.
The applicable subheading for the first and fourth listed casters - 5944 UAP 125 R26-28S45
HTC9003/WR7015 and 5947 XSC 125 R05-22X40 HT9002 CKICKWR9011 will be 8302.20.0000, HTSUS,
which provides for Base metal mountings, fittings and similar articles…Castors, and parts thereof. The rate
of duty will be 5.7 percent ad valorem.
The applicable subheading for the second, third, and fifth listed casters, 5947 UAP 125 P30-13 HTC9003
WR7015, 5940 UAP 125 P30-13 NP 7001 HTC 7001 WR7015, 5947 UAP 125 P30-13 HTC7001
KICK3000/WR7015, 594C UAP 125 P30-13 HTC7001 KICK3000/6032 WR7015, and 5947 UAP 125
P30-13 HT9002KICKWR9011, will be 3926.90.9989, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Other articles of plastics and articles of other materials of headings 3901 to
3914: Other: Other: Other.” The 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. At this time products from all 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 subheadings
8302.20.0000 or 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/.
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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division