CLA-2-90:OT:RR:NC:N3:135
Adam Gustafson
STERIS
5960 Heisley Rd
Mentor, OH 44060
RE: The tariff classification of hemostatic clips from China
Dear Mr. Gustafson:
In your letter dated August 18, 2025, you requested a tariff classification ruling. Additional information was
provided by email dated September 8, 2025.
Assurance Clip and Assurance Control Clip are sterile, single-use, hemostatic clipping devices each
consisting of three components: an applicator, a clip, and a protective cover tip. The applicator and clip are
used in a combined state and the three components are packaged and sold together. They are designed for
endoscopic clip placement within the gastrointestinal tract for endoscopic marking, hemostasis, defect
closure, and anchoring (affixing jejunal feeding tubes to the wall of the small bowel). The applicator is made
of a thumb ring, a slider, a handle, and a coil sheath. The applicator is operated by hand and not electrically
powered. It is used by the physician to control the clip's opening, closing, and deployment. The clip is made
of stainless steel and available in different sizes. It is composed of a tail and two clip arms. The clip tail is
connected to the applicator. The Assurance Clip and Assurance Control Clip have the same features except
the clip arms of the Assurance Control Clip can be adjusted by rolling the coil sheath of the device. To use
during a procedure, remove the protective tip from the clip. After confirming that the device is in the closed
position, advance the ASSURANCE Clip or Assurance Control Clip through the instrument channel of an
endoscope. When the clip is at the desired location, gently move the slider away from the thumb ring to open
the clip's jaws. The ASSURANCE Clip or Control Clip offers full 360-degree rotation, allowing for multiple
repositioning before final deployment. To permanently deploy the clip, the physician can pull the slider
proximally towards the thumb ring using a forceful, secure squeeze. After being implanted in the GI tract, the
clips will stay attached for an average of 10-14 days. The clips will then fall off on their own and be passed
through stool.
The applicable subheading for the Assurance Clip and Assurance Control Clip 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 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 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)
Denise Faingar
Acting Director
National Commodity Specialist Division