CLA-2-76:OT:RR:NC:N1:164
James Melville
Melo Co., Inc
460 Mountain Road
High Falls, NY 12440
RE: The tariff classification of a windlass from Vietnam
Dear Mr. Melville:
In your letter dated November 21, 2025, you requested a tariff classification ruling on a windlass from
Vietnam. Product information was submitted with your request.
The item under consideration is described as a windlass for a closed-loop medical emergency tourniquet used
in a battlefield situation (“MET III” Medical Emergency Tourniquet; NSN Number 6515-01-537-9259).
During tourniquet operation, a user manually rotates the windlass to tighten an attached constriction band
placed around an appendage. As the constriction band is tightened, the flow of blood from a wound
diminishes and stops. You state the windlass is composed of 7075 aluminum alloy which will be milled,
finished, and printed upon in Vietnam. As shown in a submitted drawing, the windlass is 146 millimeters
(mm) in length by 19 mm in width by 6 mm in depth. In addition, the windlass features three rectangular
cutouts measuring 41 mm in length by 8 mm in width. After importation, you state the windlasses will be
used for testing, marketing, and sampling to customers.
In your letter you suggest that the windlass for a military emergency medical tourniquet should be classified
in subheading 9018.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), the provision for
“other” instruments and apparatus used in medical, surgical, dental or veterinary sciences, and parts and
accessories thereof. We disagree. This is because the tourniquet itself is not classified under heading 9018,
HTSUS. Heading 9018 is intended for instruments and appliances primarily used in professional medical
practice for diagnosis, prevention, treatment of illness, or surgical operations. The military emergency
medical tourniquet does not meet this criterion. As the tourniquet is not classified under heading 9018,
HTSUS, its component parts, such as the windlass, also cannot be classified under subheading 9018.90.8000,
HTSUS. This position is consistent with previous rulings, New York Rulings N303210 (dated March 26,
2019) and R02451 (dated August 29, 2005), which classified similar tourniquets outside of HTSUS heading
9018.
Heading 7616, HTSUS, is a residual or basket provision which covers a wide range of aluminum articles that
are not more specifically provided for elsewhere in the HTSUS. The ENs to heading 7616 state that “This
heading covers all articles of aluminum other than those covered by the preceding headings of this Chapter,
or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specifically
covered elsewhere in the Nomenclature.” An article of aluminum can be classified in heading 7616 if it is
determined that the item is not more specifically provided for in any other heading of the tariff. Since the
aluminum windlass at issue is not classified in heading 9018, or provided for anywhere else in the tariff, it is
classifiable in heading 7616.
The applicable subheading for the windlass will be 7616.99.5190, HTSUS, which provides for “Other articles
of aluminum: Other: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 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. 9903.85.07, in addition to subheading 7616.99.5190, 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.
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 Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 7616.99.5190, 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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division