CLA-2-83:OT:RR:NC:N5:121
Desiree Ferguson
Tente Casters Inc
2266 Southpark Drive
Hebron, KY 41048
RE: The tariff classification of casters from Germany
Dear Ms. Ferguson:
In your letter dated August 22, 2025, you requested a tariff classification ruling on two casters.
The casters under consideration are described as Item 5989 UAP 150 R36-32S35 D CC, and Item 5986 UAP
150 R36-32S35 D CC. Both items are made of a steel mounting stem, and a polyamide housing and wheel.
They each have a wheel diameter of 5.91 inches (150 mm), and a wheel width of .59 inches (15 mm). These
casters will be used on a surgical robot.
In your letter, you propose classification in subheading 9402.90.0020, Harmonized Tariff Schedule of the
United States (HTSUS), as parts of medical or surgical furniture. We disagree. The surgical robot is not
surgical furniture of heading 9402, HTSUS. The device is classified in heading 9018, HTSUS as a surgical
instrument or appliance. Note 1(f) to Chapter 90 excludes parts of general use, as defined in note 2 to Section
XV, of base metal (Section XV) or similar goods of plastics (chapter 39). In this case, the subject casters fit
the description of casters in the tariff and are considered parts of general use. See Note 2(c) to Section XV.
As such, they are excluded from classification in Chapter 90.
The applicable subheading for Item 5989 UAP 150 R36-32S35 D CC, and Item 5986 UAP 150 R36-32S35 D
CC will be 8302.20.0000, HTSUS, which provides for Base metal mountings, fittings and similar
articles…Castors, and parts thereof. The rate of duty will be 5.7 percent ad valorem.
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 8302.20.0000, 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 Jennifer Jameson at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division