CLA-2-85:OT:RR:NC:N2:212
Carrie Dente
C.M.P. Canadian Medical Products Inc.
212 Earl Stewart Drive, Unit 6
Aurora L4G 6V7
Canada
RE: The tariff classification of medical lead wires from Canada
Dear Ms. Dente:
In your letter dated August 27, 2025, you requested a tariff classification ruling.
The merchandise under consideration is described as medical lead wires, Part Numbers: W6572IVRR,
W7172-12, W7472IVBB, W19472IVRRB, W4772IVRB. They are used exclusively with electro-medical
stimulation devices such as TENS, EMS/NMS devices and they are used by professional clinicians. The
cables are available in different variations of a single or dual machine-end plug(s), which are designed to
mate only with electro-medical stimulation devices. The plug(s) are attached to a single PVC insulated
conductive cable and the other end of the cable is terminated with a single or dual pin connectors that connect
to electrode patches. We note that the cables are designed to be used only to conduct the electrical signals
within the TENS/EMS/NMS electro-medical apparatus.
You suggest that the lead wires are correctly classified under the heading 9018, Harmonized Tariff Schedule
of the United States (HTSUS), as parts and accessories of electro-medical apparatus. We disagree.
Chapter 90 Note 2 (a) states “that parts and accessories which are goods included in any of the headings of
this chapter or of chapter 84, 85 or 91 (other than heading 8487, 8548 or 9033), are in all cases to be
classified in their respective headings.” Furthermore, Additional U.S. rules of Interpretation Note 1(c) states a
provision for parts of an article covers products solely or principally used as a part of such articles but a
provision for “parts” or “parts and accessories” shall not prevail over a specific provision for such part or
accessory. The items in question are goods included in a specific heading of chapter 85. As such, they are
excluded from heading 9018.
The applicable subheading for the medical lead wires, Part Numbers: W6572IVRR, W7172-12,
W7472IVBB, W19472IVRRB, W4772IVRB will be 8544.42.9090, HTSUS, which provides for “Insulated
(including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric
conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed
fibers, whether or not assembled with electric conductors or fitted with connectors: Other electric conductors,
for a voltage not exceeding 1,000 V: Fitted with connectors: Other: Other.” The general rate of duty will be
Free.
On July 30, 2025, Presidential proclamation 10962 imposed additional tariffs on certain semi-finished copper
and intensive copper derivative products. Additional duties for semi-finished copper and intensive copper
derivative products of 50 percent upon the value of the copper content are reflected in Chapter 99, heading
9903.78.01. The non-copper content of these products, provided for in heading 9903.78.02, is not subject to
the additional ad valorem duties. At the time of entry, for the copper content you must report heading
9903.78.01, in addition to subheading 8544.42.9090, HTSUS. For the non-copper content, you must report
heading 9903.78.02, in addition to subheading 8544.42.9090.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 35 percent ad valorem rate of duty. For
products covered by heading 9903.78.01 this additional duty applies to the non-copper content of the
merchandise. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in
addition to subheading 8544.42.9090, HTSUS, listed above. Articles that are entered free of duty under the
terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any
treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will
not be subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is
entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition
to subheading 8544.42.9090, HTSUS.
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 Canada are not
subject to reciprocal tariffs. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, i.e. 9903.01.26, in addition to subheading 8544.42.9090, 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