CLA-2-84:OT:RR:NC:N1:105
Shinji Azuma
Amuza Inc.
10060 Carroll Canyon Rd, Suite 100
San Diego, CA 92131
RE: The tariff classification of liquid chromatography columns from Japan
Dear Mr. Azuma:
In your letter dated June 18, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The items under consideration are described as Eicom High-Performance Liquid Chromatography (HPLC)
columns entered under model numbers CA-5ODS, SC-5ODS, CAX, PP-ODS3, AC-GEL,
AC-ENZYMPAK2, NO-PAK, and GU-GEL. The columns are designed to separate molecules based on their
chemical properties and then detect the separate molecules using electrochemical reactions. The columns
contain a stationary phase that interacts with the sample components, while the mobile phase carries the
sample through the column. Eicom systems are known for their high sensitivity and are frequently used in
neuroscience research for neurotransmitter detection.
In your letter, you have provided eight different HPLC columns for review.
The first column is the CA-5ODS, which is a reverse-phase separation column. The packed material is
octadecylsilane-bonded porous silica gel with a 5 micrometer diameter. CA-5ODS is suitable for the
separation of catecholamine analysis in an extract.
The second column is the SC-5ODS, which is a reversed-phase separation column. The packed material is
octadecylsilane-bonded porous silica gel with a 5 micrometer diameter. SC-5ODS is suitable for the
separation of monoamines and other biological samples.
The third column is the CAX, which is a 5 micrometer silica gel ion exchange column. The CAX retains and
separates cations, which are ions with a positive electrical charge, formed when an atom or molecule loses
one or more electrons. Many monoamine metabolites found in brain microdialysis samples are anionic at
neutral pH, and therefore, not easily retained on the column. It is therefore possible to get a clean
chromatogram of only the monoamines when using HPLC with electrochemical detection (ECD).
The fourth column is the PP-ODS3, which is a reversed-phase octadecylsilane bonded porous silica gel
column. EICOMPAK PP-ODS3 is suitable for the separation of dopamine and serotonin.
The fifth column is the AC-GEL, which is packed with a polymer resin and used for the analysis of
acetylcholine (ACh). It separates Choline (Ch) from the solvent front and homocholine (HCh) from ACh.
The sixth column is the AC-ENZYMPAK2, which is an immobilized enzyme column used for the analysis of
choline and acetylcholine. The column contains two enzymes, choline oxidase (EC1.1.3.17) and
acetylcholinesterase (EC3.1.1.7). The conversion efficiency is 100% due to the amount of immobilized
enzyme that is present.
The seventh column is the NO-PAK, which is a separation column used to separate nitrogen dioxide (NO2)
and nitrate ions (NO3) in biological samples. The separation mechanism is reversed-phase chromatography
and is packed with a polystyrene resin. This column is for use with Eicom’s nitric oxide analysis systems,
ENO-20 and ENO-30.
The eighth column is the GU-GEL, which is a polymer resin-based column that can be used with a wide
range of PHs, except for strong acids and alkaline PHs. The column has been developed for analyzing
glutamate with an immobilized enzyme column.
In your letter, you suggest the Eicom HPLC columns to be classified under 9027.90.8400, Harmonized Tariff
Schedule of the United States (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: Microtomes; parts and accessories:
Parts and accessories: Other: Other: Of instruments and apparatus of subheading 9027.20, 9027.30, 9027.50,
9027.81 or 9027.89.” We disagree. While the columns are used with liquid chromatographs, they are
themselves an article that is solely used for liquid separation. The Eicom HPLC columns perform the
separation and do not involve any synthesis or chemical reaction within the column itself. Chapter 90 Note
2(a) states: Parts and accessories which are goods included in any of the headings of this chapter or of chapter
84, 85 or 91 (other than heading 8487, 8548 or 9033) are in all cases to be classified in their respective
headings. Since the function of liquid separation is covered by heading 8421, HTSUS, they would
appropriately be classified in that heading.
Additionally, the Eicom HPLC columns are very similar to the SiliaChrom XT C18 HPLC Column in New
York Ruling Letter N102164 (dated May 19, 2010). The column was also used with chromatography
equipment and for the separation of liquids.
Accordingly, the applicable subheading for the Eicom HPLC columns (model numbers CA-5ODS,
SC-5ODS, CAX, PP-ODS3, AC-GEL, AC-ENZYMPAK2, NO-PAK, and GU-GEL) will be 8421.29.0065,
HTSUS, which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and
apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids:
Other: Other: Other: Other.” 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
8421.29.0065, 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