CLA-2-90:OT:RR:NC:N3: 135
Kelly Edd
Transfair North America International Freight Services, LLC dba Scan Global Logistics
18850 8th Ave S Suite 100
Seattle, WA 98148
RE: The tariff classification of a skin revitalizing tool from China
Dear Ms. Edd:
In your letter dated May 18, 2025, you requested a tariff classification ruling on behalf of The Body Firm
LLC.
The Body Firm® “Skin Revitalizing Tool” is a handheld, battery powered, palm size device that uses a
combination of vibration, heat, and LED light (blue, green, or red) therapy to improve local circulation, skin
cream absorption, and skin appearance. The device consists of a plastic cover, a massage head, a LED light,
heating film, a vibration motor, a charging port, a powder button, a print circuit board assembly, and a plastic
housing. It measures approximately 4 x 3 inches. The device is designed to be used on the face and body and
has three modes. Each mode features LED (blue, green, or red) light therapy, vibration, and heat therapy. The
vibration component has relatively higher value and weight compared to the individual heating and LED light
components. However, the differences are not significant.
Since the essential character of the device cannot be determined, it will be classified according to General
Interpretative Rule 3(c). The applicable subheading for the Skin Revitalizing Tool will be 9019.10.2020,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for handheld, battery powered
massage apparatus. 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 9019.10.2020, 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
9019.10.2020, 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