CLA-2-90:OT:RR:NC:N1:105
Paul Vroman
DHL Global Forwarding
2660 20th Street
Port Huron, MI 48059
RE: The tariff classification of a wearable wellness monitor from China
Dear Mr. Vroman:
In your letter dated June 10, 2025, on behalf of your client, Polar Electro Inc., you requested a tariff
classification ruling. Descriptive literature was provided for our review.
The item under consideration is described as the Polar 360 wearable wellness monitor, which is a wellness
monitor worn on the wrist that has a variety of activity and sleep tracking features. The Sleep Plus Stages
sleep tracking feature monitors the user’s sleep stages, including rapid eye movement (REM), light and deep
sleep, and then provides a numerical sleep score. Nightly Recharge is an overnight recovery measurement
that shows the user how well they recover from their daily activities. The Continuous heart rate feature
measures the user’s heart rate throughout the day. Together with 24/7 activity tracking, it provides the user
with a complete overview of all daily activities. The user can view the activity and sleep data in the Polar
Flow app after syncing with a smart device.
The Polar 360 wearable wellness monitor has a battery-powered module containing sensors and a Bluetooth
transmitter. The module attaches to the wrist via a textile band. The sensors in the device include an optical
heart rate (OHR) measurement sensor, an accelerometer, and a skin temperature sensor. The module
transmits the data from the sensors via Bluetooth to a software application on the user’s smart device. The
Polar 360 measures 39 mm wide by 27 mm high by 10 mm thick and weighs 17 grams. The Polar 360
wearable wellness monitor is imported with the sensor, wristband, charger, and user guidance manual.
The applicable subheading for the Polar 360 wearable wellness monitor will be 9031.80.8085, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Measuring or checking instruments,
appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and
accessories thereof: Other instruments, appliances and machines: Other: Other.” The general rate of duty will
be free.
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 9031.80.8085 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
9031.80.8085, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9031.80.8085, 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 9903.88.01 in
addition to subheading 9031.80.8085, 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/remedies/301-certain-products-china, 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 Jason Christie at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division