CLA-2-39:OT:RR:NC:N4:415
James Min
LMD Trade Law, PLLC
1629 K Street Northwest, Suite 300
Washington, DC 20006
RE: The tariff classification of plastic test strip components from Malaysia.
Dear Mr. Min:
In your letter dated November 4, 2025, you requested a tariff classification ruling on behalf of your client,
Coagusense, Inc.
Images were submitted in lieu of a sample.
There are two components of Coagusense’s prothrombin time / international normalized ratio (PT/INR) test
strips under consideration and are described as the test strip and wheel. The test strip consists of a handle, a
sample application area, and a mixing wheel and reaction well. The wheel will be attached to the test strip,
and the meter device will rotate it to mix the applied blood sample. They are both made of molded plastic.
After importation into the United States, the test strip will be assembled, and the reagent will be added to it.
Your submission indicates these two components will be imported in bulk packaging in defined, pre-counted
quantities, and they will be packaged separately but shipped together.
As this test strip and wheel would be considered articles of plastic, and as they are not more specifically
provided for elsewhere, the applicable subheading will be 3926.90.9989, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of
headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad
valorem.
In your submission, you request consideration of a secondary classification for these two items under
subheading 9817.00.96, HTSUS. This office holds the opinion that these two plastic components are not
“specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped
persons.” Further, as imported, we do not believe they would qualify as parts to the test meters referred to in
New York ruling letter N350072, dated July 1, 2025, as they are not “an integral, constituent, or component
part, without which the article to which it is to be joined, could not function as such article” as articulated in
United States v. Willoughby Camera Stores. Similarly, the test strip and wheel on their own do not
contribute to the effectiveness of these devices (e.g., facilitate the use or handling of the particular article,
widen the range of its uses, or improve its operation), so they would not be considered accessories. As such,
classification under 9817.00.96, HTSUS, would not be appropriate for these items.
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 Malaysia 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., 9903.02.39, in addition to subheading
3926.90.9989, 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 CBP Regulations (19 CFR 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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division