CLA-2-85:OT:RR:NC:N1:103
9903.88.15; 9903.88.03
Dwayne Thompson
Belluscura, LLC
5504 Democracy Dr., Ste. 200
Plano, TX 75024
RE: The tariff classification of a battery, a power supply, a cart, and power cords from China
Dear Mr. Thompson:
In your letter dated June 5, 2025, you requested a tariff classification ruling.
The first item under consideration is referred to as the X-PLOR Li-Ion Battery, model number 50188, and is
described as an eight-cell rechargeable lithium-ion battery pack with a nominal voltage of 14.4 VDC, a
nominal capacity of 6.9 Ah, and a nominal energy of 99.36 Wh. The battery cells are encased inside a plastic
enclosure with an LED indicator, a power jack, a release latch, and a connector specific to the X-PLOR
portable oxygen concentrator.
The applicable subheading for the X-PLOR Li-Ion Battery, model number 50188, will be 8507.60.0020,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries,
including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion
batteries: Other.” The general rate of duty will be 3.4 percent ad valorem.
The second item under consideration is referred to as an AC/DC power supply adapter, model number,
EDP65-15-MB2-C01, and is described as a power supply for a portable oxygen concentrator. The adapter is
equipped with an IEC C18 type female socket on one side and a short cord with a barrel connector on the
opposite side. Based on the specifications provided, the power supply converts a 120 VAC input to an output
of 15 VDC with a maximum power output of 65 Watts.
The applicable subheading for the AC/DC power supply adapter, model number, EDP65-15-MB2-C01, will
be 8504.40.9520, HTSUS, which provides for “Electrical transformers, static converters (for example,
rectifiers) and inductors; parts thereof: Static converters: Other: Rectifiers and rectifying apparatus: Power
supplies: With a power output exceeding 50 W but not exceeding 150 W.” The general rate of duty will be
free.
The third item under consideration is referred to as an AC power cord, part number 800-04 15-0011. The
cord consists of a length of insulated cable affixed at one end with a C17 type connector and a NEMA 1-15
electrical plug at the other end.
The fourth item under consideration is referred to as a DC power cord, part number 800-04 15-0010. The
subject cord consists of a length of cable affixed at one end with a barrel connector and a 12-volt automotive
power plug on the other end.
The applicable subheading for the AC power cord, part number 800-04 15-0011, and the DC power cord, part
number 800-04 15-0010, will be 8544.42.9090, HTSUS, which provides for “Insulated (including enameled
or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not
fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled
with electric conductors or fitted with connectors: Other electric conductors, for a voltage not exceeding
1,000 V: Fitted with connectors: Other: Other: Other.” The general rate of duty will be 2.6 percent ad
valorem.
The fifth item under consideration has been identified as a cart used to transport the DISCOV-R, a portable
oxygen concentrator (POC).
You have described the cart as a “custom-fitted wheeled carrying cart to support patient mobility while
utilizing a portable oxygen concentrator. The cart is a handling alternative for customers who prefer this
option over a backpack or carry bag or may present limitations for transport.”
The applicable subheading for the DISCOV-R POC cart will be 8716.80.5090, HTSUS, which provides for
“Trailers and semi-trailers; other vehicles, not mechanically propelled…: Other vehicles: Other: Other:
Other.” The general rate of duty will be 3.2 percent ad valorem.
This product may be subject to antidumping duties or countervailing duties (AD/CVD). When there is a
question as to whether merchandise is subject to an antidumping or countervailing duty order or considered
to be defined by the scope of an order, such a determination is governed by the U.S. Department of
Commerce’s International Trade Administration (Commerce). Commerce issues scope rulings to determine
whether merchandise which is in commercial production is covered by the scope of an antidumping or
countervailing duty order. Commerce’s scope rulings are separate and distinct from decisions issued by CBP
regarding tariff classification and country of origin for purposes such as duty assessment and marking.
To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide
to seeking a scope ruling can be found at
https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD
investigations at the United States International Trade Commission can be viewed on its website at
http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits
and liquidation can be searched using ACE or CBP’s search tool at
https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/.
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 8507.60.0020, 8504.40.9520, 8544.42.9090, and 8716.80.5090, 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 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
8507.60.0020, 8504.40.9520, 8544.42.9090, and 8716.80.5090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8507.60.0020, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8507.60.0020, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8504.40.9520, 8544.42.9090, and 8716.80.5090, HTSUS, unless specifically excluded, are
subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the
Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8504.40.9520, 8544.42.9090, and
8716.80.5090, 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. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 Paul Huang at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division