CLA-2-90:OT:RR:NC:N1:105
Donal O'Gorman
identifyHer Inc.
800 N King Street, Suite 304-3205
Wilmington, DE 19801
RE: The tariff classification of a Peri sensor from China
Dear Mr. O'Gorman:
In your letter dated November 21, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as a Peri sensor (model IDH-AA-01), which is a battery-powered,
body-worn electronic unit that captures bio signals and communicates them via Bluetooth to a paired
smartphone application. The device is made of a sealed polymer enclosure with a gasket, an internal printed
circuit board assembly (PCBA) carrying a microcontroller with memory, power management integrated
circuits (ICs), sensors, and a Bluetooth radio transceiver with antenna. Additionally, there are stainless-steel
electrodes, a skin-contact thermistor, an optical window for photoplethysmography (PPG) emitter/detector,
and medical-grade adhesive patches for on-body attachment. The device measures 66×45×11 mm and weighs
25 g.
The Peri sensor has a PPG (optical) for pulse/flow-related signals, electrodermal activity (EDA) electrodes
for skin conductance, a 3-axis accelerometer for motion/posture, and a skin-contact temperature sensor. In
operation, the sensors generate analog signals that are digitized by on-board electronics before being
wirelessly transmitted via Bluetooth to the paired app. Data is also synced to cloud services where it is
processed and the outputs displayed on the app.
The Peri sensor is designed as a consumer wellness wearable for trend-tracking of perimenopausal symptom
patterns (hot flashes, night sweats, sleep disruption, anxiety) as well as step count and menstrual-cycle
tracking. The device is imported with two rechargeable batteries, USB-C charging dock/cable, 20 starter
adhesive patches, and a quick-start guide.
In your letter, you suggest the applicable heading to be 8517, Harmonized Tariff Schedule of the United
States (HTSUS), which provides in relevant part for “…other apparatus for the transmission or reception of
voice, images or other data, including apparatus for communication in a wired or wireless network (such as a
local or wide area network).” The item concerned is primarily used to monitor various aspects of a person’s
wellbeing. It incorporates various sensors and a processing system that measures health related information.
It also has a secondary function of transmitting that data to a remote Bluetooth enabled device which then
transmits to a cloud-based service.
Classification under heading 8517, HTSUS, is precluded because the devices concerned are composite goods
(Section XVI Note 3 and Chapter 90 Note 3) which execute the principal function of determining/calculating
a measurement. The ability to transmit that information to a remote device would be considered the unit’s
secondary or support function. Additionally, as per the Explanatory Notes to heading 8517, carrier-current
and other transmitters and receivers which form a single unit with analogue or digital telemetering
instruments or apparatus…, are excluded from heading 8517. Measurement apparatus of Chapter 90 are also
excluded from classification within Chapter 85. (Section Note XVI Note 1(m)). As such, classification within
heading 8517, HTSUS, is not applicable.
The applicable subheading for the Peri sensor (model IDH-AA-01) will be 9031.80.8085, HTSUS, which
provides for “Measuring or checking instruments, appliances and machines, not specified or included
elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and
machines: Other: Other.” The general rate of duty will be free.
The tariffs and additional duties cited in the companion information letter 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 Jason Christie at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division