CLA-2-90:OT:RR:NC:N3:135
Michael Gamble
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The tariff classification of a walker skis, walker basket, and walker tray from China and Taiwan
Dear Mr. Gamble:
In your letter dated September 16, 2025, on behalf of your client, Walgreen Co, (“Walgreens”), you
requested a tariff classification ruling for four items. The classification of the walker glide balls will be
addressed under separate correspondence.
The walker skis (WIC 778551) are curved plastic attachments designed to fit onto the rear legs of a standard
walker. Shaped like small skis, they allow the walker to glide smoothly over various surfaces such as carpet,
tile, and pavement. Unlike rubber tips that can catch or drag, walker skis reduce friction and improve
maneuverability, making it easier for users to
push the walker without lifting it. They are especially useful for individuals who need more fluid walking
motion or who frequently use their walker outdoors. It is made in China.
The wire walker basket (WIC 875041) is an accessory that attaches to the front of a folding walker, providing
a convenient way for users to carry personal items while keeping their hands free for safe mobility. It is
constructed of steel and wrapped in plastic. The basket features four hooks specially designed to secure the
basket to the walker’s frame without the need for tools. The walker basket contains a plastic insert tray and
cup holder. It is for carrying everyday essentials such as a water bottle, a wallet, a phone, or medications. It is
made in China.
The walker tray (WIC 749215) is a plastic tray that is specifically designed to fit over the handles of a
standard walker, providing a flat, stable surface for carrying meals, drinks, books, or personal items. The
walker tray has one long slot on the left and right side. These long slots running along its short edges allow
the walker’s handles to pass through the slots, which allows the tray to settle onto the frame and mount to the
walker. The walker tray is designed with raised edges to help
prevent items from sliding off during movement and features built-in cup holders to keep beverages
secure. You state the walker tray is especially helpful for individuals who want to maintain independence
while transporting items around the home, particularly in settings such as kitchens or dining areas. The
walker tray is made in Taiwan.
The applicable subheading for the walker skis, walker basket, and walker tray will be 9021.10.0090,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]rthopedic appliances,
including crutches, surgical belts; splints and other fracture appliances …[o]rthopedic and fracture
appliances, and parts and accessories thereof: [o]ther.” The general rate of duty will be free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 9021.10.0090, HTSUS, listed above.
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 China, Hong
Kong, and Macau will be subject to an additional 10 percent ad valorem rate of duty. 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 9021.10.0090, HTSUS, listed above.
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 Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading
9021.10.0090, HTSUS, listed above.
However, the additional duties imposed heading 9903.01.24, 9903.01.25 or 9903.02.60 shall not apply to
goods for which entry is properly claimed under a provision of chapter 98 of the tariff schedule pursuant to
applicable regulations of U.S. Customs and Border Protection (“CBP”), and whenever CBP agrees that entry
under such a provision is appropriate, except for goods entered under heading 9802.00.80; and subheadings
9802.00.40, 9802.00.50, and 9802.00.60.
In your submission you requested consideration of a secondary classification under 9817.00.96, HTSUS,
which applies to articles and parts and accessories of articles specifically designed or adapted for the use or
benefit of the permanently or chronically physically or mentally handicapped.
Subheading 9817.00.96, HTSUS, covers: “[a]rticles specially designed or adapted for the use or benefit of the
blind or other physically or mentally handicapped persons; parts and accessories (except parts and
accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the
foregoing articles: [o]ther.” The term “blind or other physically or mentally handicapped persons” includes
“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.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS.
Subheading 9817.00.96, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles,
dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic
articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS.
In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308
(Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent
greater than in other cases or towards others” and “designed” means something that is “done, performed, or
made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We
must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then,
whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314. The Court of Appeals
for the Federal Circuit CAFC) clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially designed,” the
merchandise “must be intended for the use or benefit of a specific class of persons to an extent greater than
for the use or benefit of others” and adopted the five factors used by U.S. Customs and Border Protection
(CBP):
(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.
CBP has previously ruled that walkers for those with a permanent or chronic disability are eligible for
subheading 9817.00.96, HTSUS. See Headquarters Ruling Letter 556995, dated February 25, 1993, NY
rulings G88041, dated April 5, 2001, N235453, dated December 12, 2012, and N243278, dated July 18,
2013. The walker skis, walker basket, and walk tray are specifically designed for use with standard walkers
and have no other practical application. While the walker skis are optional, they are designed as a
replacement for standard walker tips, becoming an integral part of the walker to facilitate smooth movement
over various surfaces once installed. The walker basket and walk tray function as accessories specifically
designed for walkers. In a recent decision, NY ruling N347068, dated April 23, 2025, CBP determined that a
universal walker tray and a walker accessory bag, both specifically designed to be used with a standard
mobility walker, qualified for duty-free treatment under subheading 9817.00.96, HTSUS. Accordingly, we
find that the walker skis, walker basket, and walker tray are also eligible for duty-free treatment under
subheading 9817.00.96, HTSUS.
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