CLA-2-85:OT:RR:NC:N2:212
Ana Villalba Villar
StimuSIL, Inc.
2810 Church Street, PMB 78535
Wilmington, DE 19802
RE: The tariff classification of an electromagnetic stimulation device from Spain
Dear Ms. Villalba Villar:
In your letter dated November 4, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the StimuField Cap, model number SFM10001, which
is described as an electromagnetic scalp and hair stimulation device. The subject device is presented as a
traditional baseball cap, within which is an array of embedded Pulsed Electromagnetic Field (PEMF) coils
and control printed circuit board (PCB). The PEMF coils are enclosed within a plastic casing and meant to
cover the wearer’s scalp area. In use, the coils produces an electromagnetic field, which is delivered to the
scalp at various frequencies and intensities. This electromagnetic field is said to stimulate the area in order to
improve the health and appearance of the user’s hair. We note that this cap is meant for home use and is not
considered a medical device.
In your request, you suggest that the correct classification for the subject cap should be 8543.70.9860,
Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the StimuField Cap, model number SFM10001, will be 8543.70.9860,
HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or
included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.”
The general rate of duty will be 2.6% 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 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 8543.70.9860, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division