CLA-2-90:OT:RR:NC:N3 135
Kyl Kirby
Kyl J. Kirby, Attorney and Counselor at Law, P.C.
1400 Lipscomb Street
Fort Worth, TX 76104
RE: The tariff classification of foot massagers from China
Dear Mr. Kirby:
In your letter dated May 4, 2025, you requested a tariff classification ruling on behalf of MEGARUB.COM.
The products under consideration are identified as MedMassager’s Foot Massager Classic (item number
MMF-06, the company website indicates it is model number MMF-08) and Foot Massager Plus (item number
MMF-07), which feature an inclined surface. Both foot massagers measure 15” x 12” x 9.5” and feature a
full-sized foot pad with rubber nubs, an arch bar across the top of the foot pad, slip resistant feet, 110 V 60
Hz electric power, and an adjustable knob or switch to control the speed. They are nearly identical except the
classic model is 10 lbs. and has a 3,300 RPM motor and two speeds. The Plus model is 11 lbs. and has 4000
RPM motor and 11 variable speeds. Both massagers use oscillating technology that combines vibration and
circular rotation to deliver targeted pressure and oscillating massage. You state that the “[o]scillating
technology mimics the motion of a masseuse’s hands. A full-sized oscillating foot pad and arch bar target
pressure points. The unique movement of the foot pad stimulates the flow of oxygen and nutrients through
the body.” After placing the foot massagers on a hard firm surface, the user is instructed to start with the
lowest speed, place their feet on the foot pad and adjust the speed to a comfortable setting. They can also use
the arch bar on the top of the foot pad for added stimulation of toes, arch and heel. Rocking the massager
forward allows the user to stimulate the calf area and shins more effectively. The massagers are not intended
for physical exercise use.
The applicable subheading for MedMassager’s Foot Massager Classic and Foot Massager Plus will be
9019.10.2045, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“[m]echano-therapy appliances; massage apparatus …: [m]assage apparatus: [e]lectrically operated: [o]other:
[other].” The general rate of duty will be free.
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 9019.10.2045, HTSUS, listed above.
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 additional10 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 9019.10.2045, HTSUS, listed above. ??
The tariffs and additional duties cited above are current as of this ruling?s issuance. 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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division