CLA-2-90:OT:RR:NC:N1:105
Shinji Azuma
Amuza Inc.
10060 Carroll Canyon Road, Suite 100
San Diego, CA 92131
RE: The tariff classification of a wireless fiber photometry system from Japan
Dear Mr. Azuma:
In your letter dated June 16, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the TeleFipho, which is a wireless fiber photometry system
designed for real-time monitoring of neural activity using fiber optic technology. It enables researchers to
study brain activity in freely moving animals, offering flexibility and precision in neuroscience research. This
system integrates wireless capabilities, allowing researchers to collect data without tethering, thereby
reducing stress on experimental subjects and providing more natural behavioral observations.
In operation, a fiber-optic cannula is surgically implanted into the target brain region of the research animal.
A lightweight wireless headstage is attached to the implanted cannula. This headstage contains all the
necessary optical components, including a light source, optical filters, and a photodetector. Genetically
encoded fluorescent indicators are then expressed into the neurons of interest. The light source in the
headstage emits excitation light through the fiber to the target area in the brain. When neurons expressing the
fluorescent indicator become active, they fluoresce in proportion to the concentration of the molecules being
measured (e.g., calcium or neurotransmitters). Some of this fluorescent light travels back through the fiber to
the photodetector in the headstage. The headstage wirelessly transmits data from the photodetector to a base
station via radio waves. The base station transmits the collected data to a computer for real-time viewing and
analysis using TeleFipho software or other compatible software.
In your letter, you suggest the applicable subheading for the TeleFipho 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”. We disagree.
The item concerned is a complete system comprising of various components such as a cannula, which will be
surgically imparted into an animal’s brain, a headset that connects to the cannula and a base station that
receives the data from the headset. This system is a functional assembly that is manufactured beyond that of
an LED of heading 8541, HTSUS. The overall function of this system is to perform an analysis of an
animal’s neural activity, which is a function that is provided for outside of heading 8541, HTSUS.
Additionally, Section XVI Note 1 (m) excludes articles of chapter 90. As such, classification within heading
8541, HTSUS, would be excluded.
The applicable subheading for the TeleFipho will be 9027.50.4050, 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: Other
instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical:
Photometers.” The general rate of duty will be free.
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
9027.50.4050, 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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division