CLA-2-95:OT:RR:NC:N4:425
Mr. Michael Gamble
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The tariff classification of mobility canes from China and Taiwan.
Dear Mr. Gamble:
In your letter dated August 15, 2025, you requested a tariff classification ruling on behalf of your client,
Walgreen Co.
You submitted photographs and detailed descriptions of five mobility canes.
The first cane is identified as WALG Push Button Cane, Walgreens item code (WIC) 639520, which consists
of an adjustable cane made predominantly of aluminum. The cane features a convenient button on the handle
for the user to adjust the height of the cane. The handle is made of polypropylene (PP) and thermoplastic
rubber (TPR). The handle also features a wrist strap. The tip is made of TPR. The cane is from Taiwan.
The second cane is identified as WALG Adjustable 2 in 1 Stick, Walgreens item code (WIC) 739286, which
consists of an adjustable aluminum cane with a handle made of polypropylene (PP) and thermoplastic rubber
(TPR). The horizontal handle can also lock in a vertical position. The handle also features a wrist strap. The
tip is made of TPR. The cane is from Taiwan.
The third cane is identified as WALG Cane Ofst Gel Hndl Engrv Blk, Walgreens item code (WIC) 728749,
which consists of an adjustable height, aluminum cane with a thermoplastic rubber (TPR). The offset handle
features a wrist strap. The tip is made of thermoplastic rubber (TPR). The cane is from China.
The fourth cane is identified as WALG Cane T-Handle Black, Walgreens item code (WIC) 727722, which
consists of an adjustable height, aluminum cane with a Schima wood handle and a thermoplastic rubber
(TPR) tip. This cane is from China.
The fifth cane is identified as WALG Cane Offset Handle Black, Walgreens item code (WIC) 736709, which
consists of an adjustable height, aluminum cane with a foam handle and a thermoplastic rubber (TPR) tip.
The offset handle features a wrist strap. This cane is from China.
The applicable subheading for the WALG Push Button Cane, Walgreens item code (WIC) 639520, WALG
Adjustable 2 in 1 Stick, Walgreens item code (WIC) 739286, WALG Cane Ofst Gel Hndl Engrv Blk,
Walgreens item code (WIC) 728749, WALG Cane T-Handle Black, Walgreens item code (WIC) 727722,
and WALG Cane Offset Handle Black, Walgreens item code (WIC) 736709, will be 6602.00.0000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Walking sticks, seat sticks,
whips, riding crops and the like.” The column one, general rate of duty will be 4 percent ad valorem.
You have also requested the status of this merchandise under subheading 9817.00.96, HTSUS, which
provides for “Articles specially designed or adapted for the use or benefit of the blind or other physically or
mentally handicapped persons…” Chapter 98, Subchapter XVII, U.S. Note 4(a), HTSUS, defines the terms
of the subheading, “blind or other physically or mentally handicapped persons” to include “any person
suffering from a permanent or chronic physical or mental impairment.” This 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 oneself, performing manual tasks, walking, seeing, hearing, speaking,
breathing, learning, or working.” Furthermore, Chapter 98, Subchapter XVII, U.S. Note 4(b)(i) specifically
excludes “articles for acute or transient disability” from subheading 9817.00.96, HTSUS. The canes are
designed for an individual suffering from a condition that limits the major life activity of walking. The
primary question is whether the canes are articles for acute or transient disability, and therefore precluded
from treatment under 9817.00.96, HTSUS.
Headquarters ruling HQ 556532, dated 6/18/92, classified various canes. CBP determined that, even though
individuals with acute disabilities (such as sprained ankles, etc.) utilized the canes in some instances, the
canes were of the class or kind predominately used by permanently or chronically handicapped individuals.
The decision was supported and expanded upon in HQ 563142, dated 2/18/05.
Further, ruling HQ 563142 states, “Although some styles of canes are utilized as fashion accessories, the
canes at issue appear to be constructed in a manner which represents function over form.” The canes
qualified under the special provision.
The WALG Push Button Cane, Walgreens item code (WIC) 639520, WALG Adjustable 2 in 1 Stick,
Walgreens item code (WIC) 739286, WALG Cane Ofst Gel Hndl Engrv Blk, Walgreens item code (WIC)
728749, WALG Cane T-Handle Black, Walgreens item code (WIC) 727722, and WALG Cane Offset Handle
Black, Walgreens item code (WIC) 736709, all appear to function in a manner similar to the canes in the
cited rulings, and it is most likely to be used by an individual with a chronic impairment to walking. These
canes are specially designed or adapted for the handicapped and is not precluded by Note 4(b) as articles for
individuals with acute or transient disabilities. Therefore, it is eligible for duty-free treatment under
subheading 9817.00.96, HTSUS.
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/.
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 6602.00.0000, 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 6602.00.0000, 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 Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading
6602.00.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 6602.00.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, 9903.88.15, in
addition to subheading 6602.00.0000, 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.
However, the additional duties imposed by subheadings 9903.01.24, 9903.01.25, or 9903.88.15 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.
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 Sandra Carlson at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division