CLA-2-44:OT:RR:NC:4:434
Nick Koukourakis
Glidance, Inc.
3507 S. Main Street
Seattle, WA 98144
RE: The tariff classification of a mobility aid for the blind from Thailand
Dear Mr. Koukourakis:
In your letter, dated May 5, 2025, you requested a tariff classification ruling. The ruling was requested on a
mobility aid for the blind. Product descriptions and photos were provided for our review.
The product under consideration is the “Glide,” a self-guided mobility aid for the blind or individuals with
low vision. It consists of a long handle, similar to a cane, with two small wheels at the base and multiple
sensors. The user holds the handle of the Glide and pushes the device in front of them. The sensors help
blind and low vision people navigate independently, helping them to avoid obstacles, keeping them on a safe
path, making them aware of their surroundings, and enabling them to navigate to specific locations or targets.
As a user holds the handle of the device and begins to walk forward, Glide uses a variety of electronic
sensors, including 3D cameras, inertial measurement units, encoders, and ultrasonic transmitters to
understand the environment around the device. From there the onboard computer is able to process the
sensor data in real-time to provide obstacle avoidance and path-planning as the user walks with the device.
The computer and software automatically control the steering and braking, physically guiding the user
around obstacles, keeping them walking in a straight line along a path, and navigating on routes to help them
get to targets like a door, a reception desk, etc., or along a route to get to an address or destination using map
data along with our sensors.
The Explanatory Notes to heading 6602, Harmonized Tariff Schedule of the United States (HTSUS) state
that this heading includes “…walking sticks specially designed for disabled persons and senior citizens…”
Traditional tipped canes used by the blind have been classified by CBP as canes of heading 6602, HTSUS,
see HQ ruling 556532, issued June 18, 1992.
The applicable subheading for the Glide mobility device will be 6602.00.0000, HTSUS, which provides for
“Walking sticks, seat sticks, whips, riding crops and the like.” The column one, general rate of duty will be 4
percent ad valorem.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
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, 9903.01.25, in addition to subheading
6602.00.0000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status
of goods covered by the Note cited above and the applicable Chapter 99 subheading.
The additional duties imposed by these headings shall not apply to goods for which entry is properly claimed
under a provision of chapter 98 of the tariff schedule pursuant to applicable regulations of U.S. Customs and
Border Protection (CBP), and whenever CBP agrees that entry under such a provision is appropriate, except
for goods entered under heading 9802.00.80; and subheadings 9802.00.40, 9802.00.50, and 9802.00.60. For
subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duties apply to the value of repairs,
alterations, or processing performed, as described in the applicable subheading. For heading 9802.00.80, the
additional duties apply to the value of the article assembled abroad, less the cost or value of such products of
the United States, as described.
In your submission you requested consideration of a secondary classification under 9817.00.96, HTSUS.
Subheading 9817.00.96, HTSUS, covers: “Articles specially designed or adapted for the use or benefit of the
blind or other physically or mentally handicapped persons; parts and accessories (except parts and
accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the
foregoing articles . . . Other.” The term “blind or other physically or mentally handicapped persons” includes
“any person suffering from a permanent or chronic physical or mental impairment which substantially limits
one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing,
hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS.
In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308
(Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent
greater than in other cases or towards others” and “designed” means something that is “done, performed, or
made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We
must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then,
whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314.
The Court of Appeals for the Federal Circuit clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially
designed,” the merchandise “must be intended for the use or benefit of a specific class of persons to an extent
greater than for the use or benefit of others” and adopted the five factors used by CBP: (1) the physical
properties of the article itself (i.e., whether the article is easily distinguishable by properties of the design,
form, and the corresponding use specific to this unique design, from articles useful to non-handicapped
persons); (2) whether any characteristics are present that create a substantial probability of use by the
chronically handicapped so that the article is easily distinguishable from articles useful to the general public
and any use thereof by the general public is so improbable that it would be fugitive; (3) whether articles are
imported by manufacturers or distributors recognized or proven to be involved in this class or kind of articles
for the handicapped; (4) whether the articles are sold in specialty stores which serve handicapped individuals;
and, (5) whether the condition of the articles at the time of importation indicates that these articles are for the
handicapped.
Individuals who utilize the Glide aids at issue would constitute handicapped persons under Note 4(a), which
includes those individuals who have vision difficulties.? The Glide aids are specifically designed to enable the
handicapped to adapt to their disability.
Subheading 9817.00.96, HTSUS, excludes ?(i) articles for acute or transient disability; (ii) spectacles,
dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic
articles; or, (iv) medicine or drugs. U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS.
The primary question remaining is whether the Glide is an article for acute or transient disability, and
therefore precluded from treatment under 9817.00.96, HTSUS.
The traditional white and red walking canes used by blind individuals to enable them to guide themselves
while walking, have previously been determined to be eligible for duty-free treatment under subheading
9817.00.96, HTSUSA. See Headquarters Ruling Letter 555537 dated August 10, 1990.? Therefore, the Glide
mobility aid, which serves a parallel function, qualifies for 9817.00.96, HTSUS.
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 Charlene Miller at
[email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division