CLA-2-94:OT:RR:NC:N3:135

Vassana Palivan
Mizuho OSI
30031 Ahern Avenue
Union City, CA 94587

RE: The tariff classification of a castor from Finland

Dear Ms. Palivan:

In your letter dated August 15, 2025, you requested a tariff classification ruling.

Manner e-SMART castor (Part # ND0452, Model FK50X50-EJ-S-125 GPF/K) is a 125 mm single-wheel, swivel, electric central locking castor. The castor features a polyamide housing and wheel center, a wheel measuring 125 mm in diameter, a push button operated, mechanical emergency quick release lock system, and a motion sensor. Your website indicates that the castor can be locked and released at the push of a button. The locking/unlocking actuator is embedded in the wheel and connected to the control system. The wheel is placed directly on the round or square tube, making it quick to install. The motion sensor allows automatic locking. You state the primary use of the Manner castor is for the Trios surgical table.

The applicable subheading for the Manner e-SMART castor will be 9402.90.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[m]edical, surgical, dental or veterinary furniture (for example, operating tables, examination tables, hospital beds with mechanical fittings, dentists' chairs); barbers' chairs and similar chairs, having rotating as well as both reclining and elevating movements; parts of the foregoing articles: [o]ther: [o]ther.” 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 of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1- General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1- General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 9402.90.0020, 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)
Denise Faingar
Acting Director
National Commodity Specialist Division