CLA-2-90:OT:RR:NC:N3:135
Christopher Radpour
ChrisRadpourMD, LLC
846 Secret Garden Dr.
Chattanooga, TN 37421
RE: The tariff classification of a medical instrument from China
Dear Mr. Radpour:
In your letter dated July 10, 2025, you requested a tariff classification ruling.
The PessaryAssistant™ is a handheld medical tool constructed of medical-grade polypropylene plastic. It is
designed to assist with the placement and removal of vaginal pessaries, which are used in the treatment of
pelvic organ prolapse and urinary continence. It is approximately 19 cm long. It has an upside-down “U”
shaped side which is used to fold the ring pessary to place it in the vagina and a “C” shaped hook on the other
side which is used to hook the pessary and remove it from the vagina. Each tool is individually wrapped for
both clinical and personal use. It is primarily used by patients, gynecologists and urologists.
The applicable subheading for the the PessaryAssistant™ will be 9018.90.8000, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for “[i]nstruments and appliances used in medical, surgical,
dental or veterinary sciences … parts and accessories thereof: [o]ther instruments and appliances and parts
and accessories thereof: [o]ther: [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 9018.90.8000, 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,
including Taiwan, 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 subheadings 9018.90.8000, 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