CLA-2-66:OT:RR:NC:N4:425
Mr. Michael Gamble
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The tariff classification of cane tips from Thailand.
Dear Mr. Gamble:
In your letter dated September 19, 2025, you requested a tariff classification ruling on behalf of your client,
Walgreen Co.
You have submitted photographs and descriptions for three items. Walgreens item code (WIC) 586507 and
(WIC) 586337 are identified as replacement cane tips and (WIC) 586505 are identified as replacement
walker/commode tips. The subject items are replacement rubber tips, sold in pairs, the walker /commode tips
include two pairs. Each tip is made of molded rubber with steel reinforcement. The replacement tips are sized
to match the shaft diameter of canes, and feature treads on the bottom for slip resistance. Their use is to
provide a safe, durable and slip-resistant interface between the cane and the ground. These replacement tips
are imported and sold separately from the canes.
Walgreens item code (WIC) 586507, Small Base, 1/2" Diameter Quad Cane Tips, are described as
heavy-duty rubber tips with a metal reinforcement core, designed for attachment to quad canes. These items
are used as replacement tips for quad canes (canes with a four-pronged base) that have a leg outer diameter of
1/2 inch (1.3 cm). The small base is specifically engineered to fit the narrower legs of quad canes, ensuring a
secure fit and stable base for the user.
Walgreens item code (WIC) 586337, Walgreens 3/4" Diameter Cane Tips are described as heavy-duty rubber
tips with a metal reinforcement core intended to be used as replacement tips for standard, single point canes
that have a leg outer diameter of 3/4 inch (1.9 cm).
You suggest that these cane tips would be correctly classified under subheading 6603.90.8100, Harmonized
Tariff Schedule of the United States, which provides for “Umbrellas and sun umbrellas (including
walking-stick umbrellas, garden umbrellas and similar umbrellas): Parts, trimmings and accessories of
articles of heading 6601 or 6602: Other: Other,” and we agree.
The applicable subheading for the 6603.90.8100, (HTSUS), which provides for “Umbrellas and sun
umbrellas (including walking-stick umbrellas, garden umbrellas and similar umbrellas): Parts, trimmings and
accessories of articles of heading 6601 or 6602: Other: Other.” The general rate of duty will be 5.2% 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 Thailand will be
subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.61, in addition to subheading 6
603.90.8100, HTSUS, listed above.
You have also requested the status of this merchandise under subheading 9817.00.96, HTSUS, which
provides for “Articles specially designed or adapted for the use or benefit of the blind or other physically or
mentally handicapped persons…” Chapter 98, Subchapter XVII, U.S. Note 4(a), HTSUS, defines the terms
of the subheading, “blind or other physically or mentally handicapped persons” to include “any person
suffering from a permanent or chronic physical or mental impairment.”
This 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 oneself, performing manual tasks,
walking, seeing, hearing, speaking, breathing, learning, or working.” Furthermore, Chapter 98, Subchapter
XVII, U.S. Note 4(b)(i) specifically excludes “articles for acute or transient disability” from subheading
9817.00.96, HTSUS.
The primary question is whether the cane tips are articles for acute or transient disability, and therefore
precluded from treatment under 9817.00.96, HTSUS. These articles can have multiple uses for the
non-handicapped, therefore, they do not qualify and are not 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/.
Your inquiry does not provide enough information for us to give a classification ruling on (WIC) 586505,
identified as Walgreens 1 1/8" Diameter Walker/Commode Tips. Your request for a classification ruling
should include a sample. When this sample is available, you may wish to consider resubmission of your
request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please
include all of the material that we have returned to you.
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 Sandra Carlson at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division