CLA-2-90:OT:RR:NC:N3:135
Shannon Redden
Nanric, Inc.
133 S Main Street
Lawrenceburg, KY 40342
RE: The tariff classification of orthopedic appliances for foals from Germany
Dear Ms. Redden:
In your letter dated May 14, 2025, you requested a tariff classification ruling on four models of thermoplastic
polyurethane (TPU) orthopedic devices designed to correct limb deformities in foals, such as clubfoot,
angular deformities, or flaccidity. Additional information was provided by email dated June 5, 2025.
Item 1 is described as Dalric D1, D2, and D3 Heel Extensions. They are said to be therapeutic foal shoes with
heel extensions used for foals to treat weak flexor tendons (flaccidity). They feature a flat plate in the bottom
with a hole and a curve in the back to fit the curve of the hoof.
Item 2 is described as Dalric Ext1 and Dalric Ext2 (Dalric Lateral / Medial Extensions Shoes). They are said
to be therapeutic foal shoes with adjustable medial/lateral extensions to treat toe-in ankles, bowed and offset
knees, bowed hocks, knock knees and valgus hocks.
Item 3 is described as Dallmer B0, Dallmer Dalric B1 and Dallmer Dalric B2. They are said to be therapeutic
foal shoes with attachable heel wedges to treat clubfoot or contracted tendons.
Item 4 is described as Dalric C3 plastic cuff with aluminum medial/lateral extension plate, which is said to be
a therapeutic foal shoe. The C3 Plastic Cuff is fitted to the foal’s foot and then attached to the aluminum
extension plate either on the lateral or medial side to to treat toe-in ankles, bowed and offset knees, bowed
hocks, knock knees, and valgus hocks.
You explain that all of the foal shoes are therapeutic horseshoes. Most horseshoes are for protection or to
prevent wear on the foot much like tennis shoes for people. However, the therapeutic foal shoes under
consideration are each designed for a specific angular limb deformity on the foal.
As these items are only used as corrective orthopedic appliances for foals, we agree that the applicable
subheading for the products will be 9021.10.0090, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “[o]rthopedic appliances, including crutches, surgical belts and trusses; splints
and other fracture appliances …: [o]rthopedic or fracture appliances, and parts and accessories thereof:
[o]ther.” The rate of duty will be Free.
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 subheading
9021.10.0090, 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division