CLA-2-90:OT:RR:NC:N3:135
Benjamin Komar
CorLab Kft.
Fesu u. 3/B
Szeged 6726
Hungary
RE: The tariff classification of bending rubbers and switch junction ribbons from Hungary
Dear Mr. Komar:
In your letter dated September 4, 2025, you requested a tariff classification ruling. Additional information
was provided by email dated September 10, September 11, and September 12, 2025.
Item 1 is the bending rubber, a soft sheath (tubular cover) made of Viton (fluoroelastomer, which does not
meet the definition of a synthetic rubber of Chapter 40), designed to cover the distal end of a flexible
endoscope. Different flexible endoscopes necessitate different bending rubbers. The material and usage of the
bending rubbers are the same; only the length, wall thickness, and diameter change. The types are
differentiated by the following naming convention: BR [X.X]/[Y/Y] [Tapered] [Regular/Hard] [Long]. BR
refers to Bending Rubber. X.X indicates the inside diameter. Y.Y indicates the wall thickness. The imported
bending rubbers are ready to assemble as they arrive. They are attached to the endoscopes’ distal ends using
the injection molding technology. The bending rubbers are crucial components of flexible endoscopes,
enabling the devices to maneuver through tight and curved areas within the body. They provide the necessary
flexibility for the endoscopes to bend and navigate effectively during procedures.
Item 2 is identified as the Switch Junction Ribbon (SJR), model numbers SJR-180 and SJR-190, which is
described as a flexible printed circuit board (FPCB) upon which three micro-connectors are mounted. The
subject device is used within an endoscope to connect multiple microswitches and to facilitate the electrical
transmission of control signals within the scope. You state that both models are identical and only differ by
the wiring procedure.
The applicable subheading for the SJRs will be 8537.10.9170, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped
with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity...: For a
voltage not exceeding 1,000 V: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.
The applicable subheading for the bending rubbers will be 9018.19.4000, HTSUS, which provides for
“Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic
apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof:
Electro-diagnostic apparatus (including apparatus for functional exploratory examination or for checking
physiological parameters); parts and accessories thereof: Other: Apparatus for functional exploratory
examination, and parts and accessories thereof.” The general rate of duty will be free.
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 8537.10.9170 or 9018.19.4000 , 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division