CLA-2-90:OT:RR:NC:N3:135
Clinton Hansen
Millennial Medical Equipment, LLC
1736 Flagstone Dr.
St George, UT 84790
RE: The tariff classification of crutches from China
Dear Mr. Hansen:
In your letter dated June 18, 2025, you requested a tariff classification ruling. Representative pictures of the
products were provided.
The products for consideration are In-Motion forearm and underarm metal crutches. You state these crutches
are spring assisted, ergonomically designed crutches. The forearm crutches pictured in your submission have
a cuff that fits around the forearm and a handgrip. The underarm crutches have an underarm cradle that rest
under the armpit and a handgrip. In your company’s website some features are listed and may vary in
different styles. They include ergonomic handles, articulating crutch tips, spring assist on lower post, rigid
lower posts, underarm cradles, fully molded cuffs, and folding design. The crutches are packaged and sold in
pairs.
The applicable subheading for the forearm and underarm crutches will be 9021.10.0090, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “[o]rthopedic appliances, including crutches,
surgical belts; splints and other fracture appliances …[o]rthopedic and fracture appliances, and parts and
accessories thereof: [o]ther.” 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 9021.10.0090, 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
9021.10.0090, 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 Fei Chen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division