CLA-2-84:OT:RR:NC:N1:104
Shinji Azuma
Amuza Inc.
10060 Carroll Canyon Rd Suite 100
San Diego, CA 92131
RE: The tariff classification of a microdialysis sampling system from Japan.
Dear Mr. Azuma:
In your letter dated June 2, 2025, you requested a tariff classification ruling.
The Azuma AtmosLM (Large Molecule) Eicom Microdialysis System is a probe-based apparatus designed
for brain microdialysis in rodents, particularly rats and mice. This system is intended for use in neuroscience,
pharmacology, and related research fields. The Eicom Microdialysis System employs probes with
semi-permeable artificial cellulose (polyethylene) membranes to passively sample molecules from the
extracellular fluid of tissues like the brain. A perfusate fluid is pumped through the probe, and substances
from the surrounding tissue diffuse across the membrane into the perfusate. This allows researchers to collect
samples containing neurotransmitters, metabolites, and other molecules, which can then be later analyzed.
The system is for research use only and is not intended for human use or diagnostics of human or animal
disease.
As imported, the system will include a peristaltic pump, various microdialysis probes, probe accessories (e.g.,
stereotaxic adapters and guide and dummy cannulas), and other apparatus including a balance arm assembly,
tubing, a tether, a rat collar, a rat harness, and a mouse harness. The peristaltic pump uses rotating rollers to
squeeze a flexible tube, creating a peristaltic action that pushes the fluid forward, and is used to withdraw the
sample from the probe.
In your letter, you suggest the Eicom Microdialysis System be classified in subheading 9027.89.8090,
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: Other instruments and
apparatus: Other: Other: Other: Other.” We disagree. The Eicom Microdialysis System is a sample collecting
system containing a pump, tubing, and probes. It is not a machine designed for performing an analysis. Since
the device is not performing an analysis and is simply collecting the sample, heading 9027, HTSUS, is
excluded from consideration.
The applicable subheading for the Eicom Microdialysis System will be 8479.89.9599, HTSUS, which
provides for “Machines and mechanical appliances having individual functions, not specified or included
elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.”
The general rate of duty will be 2.5%.
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. Your product falls within an excepted
subheading. 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 8479.89.9599, HTSUS, listed above.
Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty
of 125 percent. Products from all other 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 subheadings 8479.89.9599, 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 the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. If 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division