CLA-2-90:OT:RR:NC:N1:105
Candice Bray
NSE Products, Inc.
75 West Center Street
Provo, UT 84601
RE: The tariff classification of spectroscopy scanner from China
Dear Ms. Bray:
In your letter dated August 15, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the Prysm iO, which is a portable, rechargeable scanner that
uses reflectance spectroscopy technology to measure carotenoid levels in the skin. It incorporates Spectral
Rai Technology, capturing over 100,000 hyperspectral absorption measurements per scan (6,000 plus per
second) to assess light absorption in the skin. An artificial intelligence (AI)-driven algorithm converts these
measurements into a “Prysm Score,” factoring out biological markers that could otherwise interfere with
accuracy.
In operation, the user places their index finger over the device lens for approximately 15 seconds while
multiple light emitting diode (LED) wavelengths are directed at the skin. The reflected light is measured to
determine carotenoid concentration. The device contains a non-removable, rechargeable lithium-ion battery
and is recharged via a USB-C cable. Each unit is packaged with the Prysm iO device, Prysm iO stand, travel
case, calibration disc, microfiber cleaning cloth, USB-C charging cable, and a quick start guide.
As suggested in your letter, the applicable subheading for the Prysm iO will be 9027.50.4060, 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: Other instruments and apparatus
using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Other.” 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 9027.50.4060, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 9027.50.4060, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9027.50.4060, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading 9903.88.01 in
addition to subheading 9027.50.4060, 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/remedies/301-certain-products-china, respectively.
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)
Denise Faingar
Acting Director
National Commodity Specialist Division