CLA-2-39:OT:RR:NC:N5:137
Tony Awad
T-Pull Door Closer
72 Laurel Street
Ottawa K1Y 3E3
Canada
RE: The tariff classification of T-pull door closers from Canada
Dear Mr. Awad:
In your letter dated November 1, 2025, you requested a tariff classification ruling.
Item 1 is described as Plastic T-Pull Door Closers, Models TP03B and TP03W. These are T-shaped handles
that can swivel 90 degrees to allow a user to pull a door shut without having to rotate their torso or shoulders.
The T-Pull is made of injection-molded acrylonitrile-butadiene-styrene (ABS) plastic. It measures 8.5 in (L)
× 2.5 in (W) × 0.5 in (H) and weighs 2.3 oz (65 g). It is attached to the door with either pre-installed adhesive
tape or it can be screwed in place for permanent installation. You state these handles are designed for
wheelchair users (limited reach/rotation), seniors with arthritis or stroke, upper and lower-limb amputees, and
people with limited strength, balance or dexterity to allow them to close a door, which could be difficult or
impossible with a standard knob or lever. The handles are sold in various retailers that sell healthcare,
adaptive, or medical supply products. They are also available online at an Amazon storefront.
Item 2 is described as Aluminum T-Pull Door Closers, Models TPA100B and TPA100C. These are T-shaped
handles that can swivel 90 degrees to allow a user to pull a door shut without having to rotate their torso or
shoulders. The T-Pull is made of CNC-machined 6061-T6 anodized aluminum. It measures 8.5 in (L) × 2.5
in (W) × 0.5 in (H) and weighs 3.9 oz (110 g). It is attached to the door with either pre-installed adhesive tape
or it can be screwed in place for permanent installation. You state these handles are designed for wheelchair
users (limited reach/rotation), seniors with arthritis or stroke, upper and lower-limb amputees, and people
with limited strength, balance or dexterity to allow them to close a door, which could be difficult or
impossible with a standard knob or lever. The handles are sold in various retailers that sell healthcare,
adaptive, or medical supply products. They are also available online at an Amazon storefront.
The applicable subheading for the Plastic T-Pull Door Closers, Models TP03B and TP03W will be
3925.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for builders’ ware
of plastics, not elsewhere specified or included: other. The general rate of duty will be 5.3 percent ad
valorem.
The applicable subheading for the Aluminum T-Pull Door Closer, Models TPA100B and TPA100C, will be
8302.41.6015, HTSUS, which provides for Base metal mountings, fittings and similar articles…Other
mountings, fittings and similar articles, and parts thereof: Suitable for buildings: Other: Of iron or steel, of
aluminum or of zinc, Suitable for interior and exterior doors (except garage, overhead or sliding doors),
doorstops, chain door fasteners, door pulls, kick plates, door knockers and escutcheons. The rate of duty will
be 3.9 percent ad valorem.
On March 12, 2025, Presidential Proclamation 10895 imposed additional tariffs on certain derivative
aluminum products. Additional duties for derivative aluminum products of 50 percent are reflected in
Chapter 99, headings 9903.85.04, 9903.85.07, and 9903.85.08. Products provided by heading 9903.85.08, as
well as products of Chapter 76 provided by 9903.85.04 and 9903.85.07, will be subject to a duty of 50
percent upon the value of the aluminum content. At the time of entry, you must report the Chapter 99 heading
applicable to your product classification, i.e. 9903.85.08, in addition to subheading 8302.41.6015, HTSUS.
Derivative aluminum articles processed in another country from aluminum articles that were smelted and cast
in the United States, provided for in heading 9903.85.09, are not subject to the additional ad valorem duties.
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. At
the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to
subheading 3925.90.0000, HTSUS, listed above. For products covered by heading 9903.85.08 this additional
duty applies to the non-aluminum 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 8302.41.6015, 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 3925.90.0000 or
8302.41.6015, 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 3925.90.0000 or 8302.41.6015, HTSUS,
listed above.
In your submission, you requested consideration of a secondary classification for the Plastic T-Pull Door
Closers, Models TP03B and TP03W and the Aluminum T-Pull Door Closers, Models TPA100B and
TPA100C, under 9817.00.96, Harmonized Tariff Schedule of the United States (HTSUS), which applies to
articles and parts 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: “Articles 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 . . . Other.” 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.
This office believes that the T-shaped design, and ability to swivel 90 degrees, distinguishes these door pulls
from a traditional stationary door pull and offers functionality that is specific to handicapped person s. They
are sold primarily at distributors that sell articles for the handicapped. The company's website and the
packaging shown on their e-commerce indicates that the door pull is used by people using a wheelchair.
Based on the information supplied, the Plastic T-Pull Door Closers, Models TP03B and TP03W and the
Aluminum T-Pull Door Closers, Models TPA100B and TPA100C, satisfy the 5 factors set out by CBP. As a
result, it is the opinion of this office that a secondary classification will apply in subheading 9817.00.96,
HTSUS.
The additional duties imposed by 9903.85.08; 9903.01.10; 9903.01.26 shall not apply to goods for which
entry is properly claimed under subheading 9817.00.96 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.
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 Christina Allen at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division