CLA-2-90:OT:RR:NC:N3:135
Myrna Nickelsen
Core Mobility Solutions, Inc.
6341 San Ignacio Ave
San Jose, CA 95119
RE: The tariff classification of LifeGlider from China
Dear Ms. Nickelsen:
In your letter dated November 14, 2025, you requested a tariff classification ruling.
The LifeGlider is a patented mobility assistance device designed for individuals who have difficulty walking
or standing due to neurological, muscular, or balance impairments. Unlike standard rollators or walkers that
require upper-body support, the LifeGlider transfers the user’s body weight through the hips and pelvis to the
frame, enabling upright and hands-free mobility.
The device consists of two parallel side tubular steel frames joined by a hinge arm structure, a braking
system, height-adjustable components to accommodate different users, a walking seat that bears part of the
user’s weight, four wheels (front swivel, rear locking), and a seatbelt-style securing system that fastens
around the waist to keep the user safely positioned while walking or standing. This configuration allows the
user to move freely while preventing falls and eliminating the need to hold the frame for balance. The
LifeGlider is shipped fully assembled. The device provides controlled mobility and fall prevention for
individuals with compromised balance, strength, or endurance. It is used in home, rehabilitation, and clinical
environments by individuals with conditions such as multiple sclerosis, Parkinson’s disease, ataxia, cerebral
palsy, or those in post-stroke recovery.
You state that the LifeGlider is exclusively designed for individuals with physical impairments that affect
their ability to walk or maintain balance. These impairments are typically long-term and may result from
medical conditions such as cerebral palsy, multiple sclerosis, Parkinson’s disease, muscular dystrophy,
stroke, traumatic brain injury, or spinal cord injury. The LifeGlider provides upright, hands-free mobility and
fall prevention by supporting the user’s pelvis and hips rather than requiring arm strength for balance. It is
not suitable or marketed for general public use.
Based on internal sales data and customer feedback, the majority of LifeGlider users — approximately 95%
— have permanent or chronic mobility impairments. A small percentage (less than 5%) use the LifeGlider
temporarily during rehabilitation following injury or surgery. In all cases, users experience substantial
mobility limitations.
The LifeGlider is unsuitable for non-disabled users due to its pelvic support system and structural design,
which restrict normal gait but stabilize users with impaired balance. The product’s weight and controlled
movement features make it cumbersome and unnecessary for able-bodied individuals. It is distributed
exclusively through medical suppliers, rehabilitation professionals, and our own website. It is not marketed in
general consumer retail channels.
The LifeGlider is used by individuals with substantial limitations in walking or standing, regardless of
whether those impairments are permanent or temporary. Examples include individuals recovering from stroke
or surgery, and those with degenerative neurological conditions such as multiple sclerosis or Parkinson’s
disease. In all cases, the LifeGlider serves to compensate for a physical disability by providing stability,
weight support, and fall prevention.
The applicable subheading for the LifeGlider will be 9021.10.0090, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “[o]rthopedic appliances, including crutches, surgical belts and
trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances
which are worn or carried, or implanted in the body, to compensate for a defect or disability; parts and
accessories thereof: [o]rthopedic or 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 10 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 ad valorem rate of duty of 10 percent. 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.
However, the additional duties imposed by headings 9903.01.24 and 9903.01.25 shall not apply to goods for
which entry is properly claimed under certain provisions of Chapter 98 of the Harmonized Tariff Schedule of
the United States (HTSUS).
In your submission you requested consideration of a 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: “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.
Based on the information provided, the LifeGlider is specially designed for individuals with physical
impairments affecting their ability to walk or maintain balance. These users are considered physically
handicapped because their permanent or chronic physical impairment substantially limits major life activities,
such as walking. CBP has previously ruled that similar mobility assistance devices, rollators and walkers, are
eligible for subheading 9817.00.96, HTSUS. See Headquarters Ruling Letters (HQ)561117 (November 16,
1998), New York Ruling Letters (NY) N235453 (December 12, 2012), and N325579 (May 5, 2022).
Accordingly, a secondary classification will apply for the LifeGlider under subheading 9817.00.97, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division