CLA-2-94:OT:RR:NC:N4:463
Laura Oliver
A N Deringer
173 West Service Road
Champlain, NY 12919
RE: The tariff classification of a safety bed rail from Taiwan
Dear Ms. Oliver:
In your letter dated May 15, 2025, you requested a tariff classification ruling, on behalf of your client,
Healthcraft Products, Inc. This ruling will address item 1 (the Smart-Rail SRS-S) from previously submitted
ruling request N349070. The other items will be addressed separately.
The Smart-Rail SRS-S, item no. DC103-RevE, is an accessory bed rail designed to facilitate the user’s entry
and exit from bed. It has two floor-standing supports (feet), a tubular metal frame in the form of a large
rectangle that slides between the mattress and the mattress foundation, and a tether that extends from the far
side of this large rectangular frame and latches onto the bedframe on the far side of the mattress—all
designed to make the bed rail secure and enable it to hold up to 300 lbs. One side of the bed rail pivots out
from the bed at a right angle (approximately 16 inches) for added versatility. Once installed, the exposed bed
rail is 16.25" wide and can be adjusted to a maximum height of 27.25". It is made in Taiwan and weighs
approximately 10 lbs. See the following image:
You stated the following:
Product Description:
The Smart-Rail, SRS-S, is an easy to assemble bedside accessory designed for independence and style. It
offers a supportive bar for nighttime turning and a sturdy handle for getting up. Its pivoting design swings
out for standing support and tucks away neatly, keeping your bedroom tidy. It is made from alloy steel and
has a weight capacity of 300 lbs. The rail diameter is 1.5” and the rail length is 16.25”. It comes with a
lifetime warranty.
Product Function & Intended Use:
The Smart-Rail can be unlocked from the bed, and moved in front while also being reversible, allowing it to
pivot correctly when installed on either side of the bed. This allows for ergonomic gripping and support for
full standing motion.
There are two different positions for support: Open (for standing support) and Closed (for in-bed
positioning). The open rail moves to center your gravity safely—no twisting and reaching needed.
Product Marketing:
Smart-Rail is sold to medical equipment stores and mobility specialty stores. Healthcraft Products Inc.
manufactures items designed to focus on fall prevention and to promote safety for disabled persons.
The provided literature states the following:
The Smart-Rail is a bed rail with 2 positions: closed and opened. In the closed position, the rail is latched to
the support frame to assist with in-bed positioning. In the opened position, the rail is unlatched from the
support frame and pivoted out to the optimal location to assist with sitting and standing. The Smart-Rail is
intended only for moderate vertical load bearing to provide bed positioning, sitting and standing support for
people with reduced mobility. The Smart-Rail is installed between the mattress and box spring and is
secured in place with a safety strap. In the closed position, the Smart-Rail is height adjustable to
accommodate the thickness of the mattress. In the opened position, the Smart-Rail is height adjustable to
accommodate the height of the user. The maximum user weight for this product is 300 lbs. The literature
also says, “The Smart-Rail is not to be used on electric or hospital style beds. The Smart-Rail is not to be
used with light-weight mattresses, and the mattress must fully cover base frame.
You suggested a primary classification in subheading 9403.99.9045, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Other furniture and parts thereof: Parts: Other: Other:
Other…Other: Other”.
You suggested a secondary classification in subheading 9817.00.96, HTSUS, noting that the ADA-Compliant
Smart-Rail is “specially designed or adapted” for the handicapped within the meaning of the Nairobi
Protocol.
Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). GRI
1 provides that the classification of goods shall be determined according to the terms of the headings of the
tariff schedule and any relative section or chapter notes. If the goods cannot be classified solely based on
GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may
then be applied in order.
In understanding the language of the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity
Description and coding System, which constitutes the official interpretation of the Harmonized System at the
international level, may be utilized. The ENs, although not dispositive or legally binding, provide a
commentary on the scope of each heading and are generally indicative of the proper interpretation of the
HTSUS. The ENs to Chapter 94 of the HTSUS state, in relevant part, for the purposes of this Chapter, that
the term “furniture” means: (A): Any “movable” articles (not included under other more specific headings of
the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or
ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres,
cinemas, offices, churches, schools, cafés, restaurants, laboratories, hospitals, dentists, surgeries, etc., or
ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport…. The subject
article is within the meaning of furniture as described by the General ENs to Chapter 94 of the HTSUS.
Since the subject article is composed of different materials (steel, foam, plastic, etc.), it is considered a
composite good for tariff purposes. The Explanatory Notes to the HTSUS, GRI 3(b) (VIII) state that “the
factor which determines essential character will vary between different kinds of goods. It may, for example,
be determined by the nature of the materials or components, its bulk, quantity, weight, or value, or by the role
of a constituent material in relation to the use of the goods.” When the essential character of a composite
good can be determined, the whole product is classified as if it consisted only of the material or component
that imparts the essential character to the composite good.
This office finds that the essential character of the subject bed rail is imparted by the steel frame, as it is
overwhelmingly predominant and is the primary material responsible for the article’s function of providing
support and stability to a person climbing into and out of bed. The applicable subheading for the Smart-Rail
SRS-S, item no. DC103-RevE, will be subheading 9403.20.0050, HTSUS, which provides for “Other
furniture and parts thereof: Other metal furniture: Household: Other: Other.” The general rate of duty will be
free.
The requester asked for the secondary classification of this bed rail under subheading 9817.00.96, HTSUS,
which provides for “[a]rticles specially designed or adapted for the use or benefit of the blind or other
physically or mentally handicapped persons….” Chapter 98, Subchapter XVII, U.S. Note 4(a), HTSUS,
defines the terms of the subheading, “blind or other physically or mentally handicapped persons” to include
“any person suffering from a permanent or chronic physical or mental impairment.” This includes any
person suffering from a permanent or chronic physical or mental impairment “which substantially limits one
or more major life activities, such as caring for oneself, performing manual tasks, walking, seeing, hearing,
speaking, breathing, learning, or working.” Chapter 98, Subchapter XVII, U.S. Note 4(b)(i) specifically
excludes “articles for acute or transient disability” from subheading 9817.00.96, HTSUS. The primary issue
is whether the bed rail is specially designed or adapted for the “use or benefit of the handicapped” and falls
within the meaning of Nairobi Protocol.
This office notes that the subject bed rail is not the light-duty type used to keep a young child from falling out
of bed, nor is it the heavy-duty type used in hospitals or nursing homes. However, this office is of the
opinion that a medium-duty bed rail such as this one, with robust construction, floor-standing stabilizer feet,
a tethered mattress anchor and capable of supporting up to 300 lbs., will be used by a person suffering from a
permanent or chronic physical impairment that substantially limits one or more major life activities, such as
caring for oneself, performing manual tasks, walking…, etc. (See N330533.) Furthermore, it is noted that
this bedrail will facilitate the movement of a person with a permanent or chronic physical impairment into
and out of bed and is similar in function to certain grab rails that have consistently received tariff preference
under the secondary classification 9817.00.96, HTSUS. (See N328828, N310613 and N304830.) Based on
the foregoing, the secondary subheading 9817.00.96, HTSUS, is applicable.
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 Seth Mazze at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division