CLA-2-85:OT:RR:NC:N4:410
Mark Presser
Walker Light, LLC
9600 Cattaraugus Avenue
Los Angles, CA 90034
RE: The tariff classification of a walker light from China
Dear Mr. Presser:
In your letter dated August 11, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Walker Light. The Walker Light consists of a
roughly rectangular plastic housing with three LED lamps in the front, five LED lamps in the reverse side,
and three switches labeled “AUTO”, ”MAN” and “LIGHT”. Extended from the bottom of housing are two
clips to fasten the light onto a cylindrical a thin object, e.g., the provided images depict the light being
clipped onto the front of a (United States Department of Veterans Affairs, or VA-issued) walker. One of the
images in your submission also shows that the Walker Light is being attached to the walker by a fastener
from the back of the housing.
The applicable subheading for the Walker Light will be 8513.10.4000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “Portable electric lamps designed to function by their own source
of energy (for example, dry batteries, storage batteries, magnetos), other than lighting equipment of heading
8512; parts thereof: Lamps: Other." The general rate of duty will be 3.5 percent ad valorem.
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 8513.10.4000, 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
8513.10.4000, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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/.
However, the additional duties imposed by subheadings 9903.01.24 or 9903.01.25 shall not apply to goods
for which entry is properly claimed under a provision of chapter 98 of the tariff schedule pursuant to
applicable regulations of U.S. Customs and Border Protection (“CBP”), and whenever CBP agrees that entry
under such a provision is appropriate, except for goods entered under heading 9802.00.80; and subheadings
9802.00.40, 9802.00.50, and 9802.00.60.
In your submission, you provide the following information regarding the Walker Light:
Purposes and Intended User Group
The Walker Light is a new, patented assistive device, specifically designed and adapted for individuals with
mobility and vision-related impairments, including:
Individuals who are legally blind or have low vision
Individuals with balance disorders, neurological conditions, or gait instability
Elderly and disabled veterans at elevated risk of falls
Specialized Features Not Found in Commercial Products
The Walker Light incorporates unique, purpose-built features not available in standard consumer devices.
These include automatic and manual features:
Dual-beam lighting system featuring three forward-facing and two downward-facing super-bright
LEDs. Engineered to illuminate both the area ahead and the ground below: a) to help prevent tripping
or falling on obstacles, such as slippers, when getting out of bed at night; and, b) to reduce the risk of
tripping or falling while walking in dark or poorly lit environments.
High-contrast activation button and toggle switch designed for visually impaired users
Multi-frequency fall alarm designed to satisfy VA audiology protocols, to alert caregivers
Lights that flash if a user falls, to alert caregivers
Customized mounting brackets for VA-issued Drive Medical Nitro F22 and Dolomite walkers
Automatic low-light activation via ambient light sensor
Automatic motion- and sound-based activation via integrated sensors
Manual operation with automatic “off” after an extended period
Rechargeable power unit with multi-hour battery life, USB charging, with a magnetically attached
breakaway cord designed to prevent tripping
Exclusive Use for Disabled Individuals
The Walker Light is expressly not intended for the general consumer market. Its functionality, design, and
features are specifically tailored to meet the needs of individuals with disabilities.
End Use and Distribution
The Walker Light is being supplied directly to the U.S. Department of Veterans Affairs, specifically to its
Low Vision and Blind Rehabilitation Department. Walker Light, LLC will also be partnering with the VA to
conduct a healthcare improvement study and provide in- home product training for Veterans. Walker Light,
LLC is an authorized U.S. Government vendor.
Development in Collaboration with the VA
The Walker Light was developed in close consultation with the VA's Low Vision and Blind Rehabilitation
team to meet its clinical and operational requirements. Falls among elderly and disabled Veterans result in
billions of dollars in annual VA medical costs. The Walker Light is specifically engineered to reduce falls
and associated medical expenses.
As such, you request consideration of a secondary classification under 9817.00.96, HTSUS, which applies to
articles and parts and accessories of articles specifically designed or adapted for the use or benefit of the
permanently or chronically physically or mentally handicapped. Subheading 9817.00.96, HTSUS, covers:
“[a]rticles specially designed or adapted for the use or benefit of the blind or other physically or mentally
handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb
prosthetics) that are specially designed or adapted for use in the foregoing articles: [o]ther.”
The term “blind or other physically or mentally handicapped persons” includes “any person suffering from a
permanent or chronic physical or mental impairment which substantially limits one or more major life
activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking,
breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS.
Subheading 9817.00.96, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles,
dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic
articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS.
In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308
(Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent
greater than in other cases or towards others” and “designed” means something that is “done, performed, or
made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We
must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then,
whether “those persons [are] physically handicapped.” Sigvaris, 899 F.3d at 1314.
The Court of Appeals for the Federal Circuit CAFC) clarified in Sigvaris, 899 F.3d at 1314-15, that to be
“specially designed,” the merchandise “must be intended for the use or benefit of a specific class of persons
to an extent greater than for the use or benefit of others” and adopted the five factors used by U.S. Customs
and Border Protection (CBP), which are:
(1) the physical properties of the article itself (i.e., whether the article is easily distinguishable by properties
of the design, form, and the corresponding use specific to this unique design, from articles useful to
non-handicapped persons); (2) whether any characteristics are present that create a substantial probability of
use by the chronically handicapped so that the article is easily distinguishable from articles useful to the
general public and any use thereof by the general public is so improbable that it would be fugitive; (3)
whether articles are imported by manufacturers or distributors recognized or proven to be involved in this
class or kind of articles for the handicapped; (4) whether the articles are sold in specialty stores which serve
handicapped individuals; and, (5) whether the condition of the articles at the time of importation indicates
that these articles are for the handicapped.
CBP has previously ruled that walkers for individuals with a permanent or chronic disability are eligible for
subheading 9817.00.96, HTSUS. Please see Headquarters Ruling Letter 556995, dated February 25, 1993 and
NY rulings G88041, dated April 5, 2001, N235453, dated December 12, 2012, and N243278, dated July 18,
2013. Regarding your claim of duty-free treatment under 9817.00.96, HTSUS, for the Walker Light, the
merchandise is specially designed to be attached to a walker, intended for the use or benefit of a specific class
of persons to an extent greater than for the use or benefit of others” and adopted the aforementioned five
factors used by CBP, thus, a secondary classification will also apply for the Walker Light in subheading
9817.00.96, HTSUS. See New York Ruling N347068, dated April 23, 2025.
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 Michael Chen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division