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 laboratory autosampler from the Netherlands
Dear Mr. Azuma:
In your letter dated June 6, 2025, you requested a tariff classification ruling.
The Spark Holland Alias Insight Autosampler Cool (Autosampler) is an advanced autosampler designed for
analytical laboratories. It is used to automatically move and inject liquid samples into High-Performance
Liquid Chromatography (HPLC) systems. The Autosampler employs a refrigerated compartment to keep the
samples cool to preserve their integrity during storage and analysis. The Autosampler itself does not perform
analysis but rather prepares the sample for analysis.
In your letter, you suggest the Autosampler should be classified in subheading 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.” We disagree. The Insight Autosampler is not a liquid
chromatograph and instead is the device that moves and injects the sample into a liquid chromatograph. We
find the subject device to be somewhat similar to the autosampler in Headquarters Ruling H273338 dated
September 30, 2019. Like the product in H273338, the Autosampler moves and automatically injects the
liquid samples into the HPLC systems. Since the device is not performing the analysis, heading 9027,
HTSUS, is excluded from consideration.
The applicable subheading for the Spark Holland Alias Insight Autosampler Cool 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 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