CLA-2-85:OT:RR:NC:N2:212
Louise Mostyn
Re-Time Pty Ltd
18 Sheriffs Road, South Australia
Lonsdale 5160
Australia
RE: The tariff classification of a light therapy device from Australia
Dear Ms. Mostyn:
In your letter dated August 25, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Retimer 3, which is further described as a wearable
light therapy device. The subject article is comprised of a lightweight plastic frame designed in the form of a
pair of eyeglasses with no lenses. Within the frame is an array of blue and green LED lights and a
rechargeable lithium-ion battery. In use, the subject device is worn on the face and emits therapeutic light in a
specific spectrum onto the eyes of the user. This light is meant to improve sleep and wake patterns.
In your request, you suggest that the correct classification for the light therapy device is under subheading
8543.70, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the Retimer 3 will be 8543.70.9860, HTSUS, which provides for “Electrical
machines and apparatus, having individual functions, not specified or included elsewhere in this chapter;
parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6
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 Australia 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
8543.70.9860, 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 Luke LePage at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division