CLA-2-90:OT:RR:NC:N1:105
Shinji Azuma
Amuza Inc.
10060 Carroll Canyon Road, Suite 100
San Diego, CA 92131
RE: The tariff classification of a liquid chromatography device from Japan
Dear Mr. Azuma:
In your letter dated May 20, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the Eicom High-Performance Liquid Chromatography with
Electrochemical Detection (HPLC-ECD) System, which is designed for sensitive and selective analyses of
electroactive compounds. It combines HPLC’s separation capability with the detection sensitivity of
electrochemical methods. The system is used in neuroscience, pharmacology, and related research fields. The
components are non-biological and not intended for human use or for diagnostics of human or animal
disease. The device measures 290 mm wide by 380 mm deep by 435 mm high and weighs 23.2 kg.
This HPLC-ECD system is a high-performance liquid chromatography system using an electrochemical
detector. Once the sample to be analyzed is injected into the system, it is fed into the analytical column by a
precision feed pump with minimal pulsatile flow, and the target substances are sequentially separated and
measured with high sensitivity by the electrochemical detector.
Electrochemical detectors (ECDs) detect the transfer of electrons associated with the redox of solutes due to
the potential between electrodes in contact with the solution and are approximately a thousand times more
sensitive than ultraviolet absorbance detectors (UV detectors), which are commonly used as detectors for
HPLC. This high sensitivity and selectivity make the ECD a powerful tool for the analysis of trace
constituents in complex matrices of biological samples.
An ECD measures the current (or electric quantity) produced when a solute is oxidized or reduced on an
electrode. Electrolytic oxidation results from the capture of electrons from a compound at an electrode.
Electrolytic reduction occurs with the donation of electrons from an electrode to a compound. The
accumulated electrons produced in this process are the current, known as the electrolytic current. Since the
strength of this electrolytic current is proportional to the concentration of a substance, detection and
measurement of the electrolytic current enables precise measurement of the target substance.
The ECD cell incorporates a 3-pole potentiostatic flow cell. The potential regulated electrolytic system of the
3-pole potentiostat is equipped with a working electrode, a reference electrode, and a counter electrode.
When a constant voltage is applied between the working electrode and the counter electrode with respect to
the reference electrode, an electrolytic reaction occurs on the working electrode as the electrochemically
active solute elutes from the column and passes through contact with the electrode in the flow cell. The main
substances to be measured with ECD are oxidizable substances.
As you suggest in your letter, the applicable subheading for the Eicom High-Performance Liquid
Chromatography with Electrochemical Detection (HPLC-ECD) system will be 9027.20.5060, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus for physical or
chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis
apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface
tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light
(including exposure meters); microtomes; parts and accessories thereof: Chromatographs and electrophoresis
instruments: Electrical: Liquid chromatographs.” The general 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
9027.20.5060, 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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division