CLA-2-87:OT:RR:NC:N1:164
Daniel Stjernlof
Feal Ramp Inc.
150 N Michigan Ave.
Chicago, IL 60601
RE: The tariff classification of aluminum ramps from Sweden
Dear Mr. Stjernlof:
In your letter dated August 20, 2025, you requested a tariff classification ruling regarding two models of
aluminum ramps from Sweden. Product information was submitted with your request.
The first items under consideration, the iRAMP Vehicle models, are described as foldable aluminum ramps
for fixed installation into vehicles. You state the ramps provide individuals with physical disabilities a safe
and accessible means to enter and exit vehicles. The ramps feature floor mounting plates which fasten to an
interior vehicle surface and a lower transition plate which rests on the ground when the ramp is extended. The
submitted materials indicate the ramps are constructed in two or three-piece variants and will be imported in
assorted sizes. Some models feature wheels attached to the lower transition plate to assist with folding and
unfolding. The ramps feature non-slip surfaces and adjustable end profiles for compatibility with manual and
powered wheelchairs.
The next items under consideration, the iRAMP Portable models, are described as lightweight, foldable
aluminum ramps to assist individuals with physical disabilities overcome architectural height barriers at
homes, public buildings, and during travel. During use, one end of the ramp is extended and placed on an
elevated surface and the other end is placed on a lower surface to provide individuals in wheelchairs the
means to travel to and from elevated areas. The ramps come in telescopic or suitcase variants and are
designed for portability. Furthermore, you state all models feature non-slip surfaces, ergonomic handles, and
side safety profiles.
The applicable subheading for the iRAMP Vehicle ramps will be 8708.99.8180, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for Parts and accessories of the motor vehicles of heading
8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other. The general rate of duty will be
2.5 percent ad valorem.
The applicable subheading for the iRAMP Portable ramps will be 7616.99.5190, HTSUS, which provides for
Other articles of aluminum: Other: Other: Other: Other: Other: Other. The general rate of duty will be 2.5
percent ad valorem.
On March 12, 2025, Presidential proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.07, in addition to subheading 7616.99.5190, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, are not subject to the additional ad valorem duties.
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. For products covered by heading 9903.85.07, this additional duty applies to the non-aluminum
content of the merchandise. 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 subheadings 8708.99.8180 and 7616.99.5190, HTSUS,
listed above.
In your submission you requested consideration of a secondary classification for the subject ramps under
9817.00.96, HTSUS, which applies to articles and parts of articles specifically designed or adapted for the
use or benefit of the permanently or chronically physically or mentally handicapped. Chapter 98, Subchapter
XVII, U.S. Note 4(a), HTSUS, defines the term blind or other physically or mentally handicapped persons as
including “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.”
In T.D. 92-77, dated August 3, 1992 (26 Cust. Bull. 35, dated August 26, 1992), Customs set forth its
position regarding certain issues arising under the Nairobi Protocol. The first issue concerned the
interpretation of the term specially designed or adapted. Customs pointed out that a primary factor to be
considered in determining whether an article was specially designed and adapted was whether the article was
easily distinguishable, by properties of the design and the corresponding use specific to this unique design,
from articles useful to non-handicapped individuals. Therefore, if an article is solely dedicated for use by the
handicapped it is Customs position that this would be conclusive evidence that the article is specially
designed or adapted for the handicapped for purposes of the Nairobi Protocol.
In Headquarters Ruling Letter 556449 dated May 5, 1992, CBP set forth five factors it would consider in
determining whether an article is specially designed or adapted for the use or benefit of handicapped persons.
These factors include: (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.
Based on the available information, the iRAMP Vehicle and iRAMP Portable ramps under consideration are
specifically designed and manufactured for use by individuals with permanent or chronic physical
disabilities. Specifically, the subject ramps facilitate the safe movement of wheelchairs in and out of vehicles
or to and from elevated areas. As described, they are constructed and sized to specification for compatibility
with wheelchairs. Moreover, both models are principally marketed to individuals with permanent or chronical
physical disabilities for use with wheelchairs. Due to the design of the merchandise, use by the general public
is improbable to the extent that it would be considered fugitive. As such, the ramps satisfy the description set
forth in Chapter 98, Subchapter XVII, U.S. Note 4(a) and none of the exclusions apply.
Therefore, we agree that a secondary classification under 9817.00.96, HTSUS, applies, and the subject items
will be free of general duty, additional duties under 9903.02.20, 9903.85.07, and the Merchandise Processing
Fee upon importation into the United States.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division