CLA-2-85:OT:RR:NC:N1:105
Shinji Azuma
Amuza Inc
10060 Carroll Canyon Rd.
San Diego, CA 92131
RE: The tariff classification of a optogenetics system from Japan
Dear Mr. Azuma:
In your letter dated June 16, 2025, you requested a tariff classification ruling.
The item under consideration is described as the Teleopto, which is a wireless optogenetics system designed
to be used in neuroscience research laboratories in order to manipulate certain brain function. The subject
system consists of a wireless receiver, remote controller, infrared emitter, LED fiber optic (cannula) insertion
tool, AC adapter and dummy receiver for habituation.
The LED fiber optic is surgically implanted into the brain of a small target animal, such as a laboratory
mouse, and a wireless receiver is attached to the end of the fiber optic. Then the remote controller with the IR
emitter is used by the researcher to send signals to the wireless receivers to trigger light pulses. The remote
controller controls the timing and intensity of light stimulation by sending infrared signals to the
receiver. The wireless receiver is a lightweight device that sits on the animal's head and receives the infrared
signals from the remote controller. The fiber optic cannula is a small, implanted fiber that delivers light from
the receiver to the specific brain region of interest.
In operation, the researcher programs the remote controller to deliver specific light pulses (or continuous
light) at a desired frequency and duration. The remote controller sends an infrared signal to the receiver on
the animal's head. The receiver then activates the LED at the tip of the fiber optic cannula, delivering the
light to the targeted brain area. The researcher can observe different behaviors from the target animal
depending on the type of light pulse or stimulation. This wireless system enables unrestricted movement of
the animal by eliminating the physical limitations associated with wired systems, thereby mitigating
stress-induced variables and improving the quality of scientific research.
In your letter, you suggest the applicable subheading for the Teleopto to be 8541.41.0000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Semiconductor devices (for example, diodes,
transistors, semiconductor-based transducers)…: Photosensitive semiconductor devices, including
photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED):
Light-emitting diodes (LED).” The item concerned is a complete system comprising various components
such as a fiber optic cannula, which will be surgically implanted into an animal’s brain and a wireless
receiver is connected to the cannula. This system is a functional assembly that is manufactured beyond that of
an LED of heading 8541, HTSUS. As such, classification within heading 8541, HTSUS would be
inapplicable.
The applicable subheading for the Teleopto will be 8543.70.9860, HTSUS, which provides for “Electrical
machines and apparatus, having individual functions, not specified or included elsewhere in this chapter;
parts thereof: Other machines and apparatus: Other: Other.” The general rate of duty will be 2.6% 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
8543.70.9860, 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 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 Luke LePage at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division