CLA-2-39:OT:RR:NC:N4:415
Rachel A. Retana
GTI Consulting
500 White Bud Lane
Fort Worth, TX 76131
RE: The tariff classification of plastic peelable heat shrink tubing from Japan.
Dear Ms. Retana:
In your letter dated June 9, 2025, you requested a tariff classification ruling on behalf of your client,
Junkosha USA, Inc.
A sample was provided and will be retained as requested.
The product under consideration is listed in your submission as Junkosha peelable heat shrink tubing. It is
constructed from a fluoropolymer blend (FEP) which would be considered a plastic material. This tubing
serves as a manufacturing aid to apply compression in catheter production processes such as bonding
lamination and tip-forming. It is specifically designed for easy removal post manufacturing to minimize
removal time and reduce the risk of catheter damage.
In your request, you suggested that this product should be classified under subheading 3917.32.0050,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Note 8 to chapter 39 states, “[f]or
the purposes of heading 3917, the expression ‘tubes, pipes and hoses’ means hollow products, whether
semimanufactures or finished products, of a kind generally used for conveying, conducting or distributing
gases or liquids (for example, ribbed garden hose, perforated tubes).” The instant product does not convey,
conduct, nor distribute gases or liquids but is a cover for a catheter that is designed to be easily peeled off and
discarded. Therefore, this tubing would be excluded from classification in subheading 3917.32.0050,
HTSUS.
As Junkosha’s peelable heat shrink tubing would be considered an article of plastic, and as it is not more
specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, which
provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther:
[o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem.
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
3926.90.9989, HTSUS, listed above.
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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division