CLA-2-40:OT:RR:NC:N5:137
Mr. Michael Gamble
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The tariff classification of walker tips from China
Dear Mr. Gamble:
In your letter, dated November 7, 2025, you requested a binding tariff classification ruling on behalf of your
client, Walgreen Company. The request was returned to you for additional information, which was submitted
on December 12, 2025. The ruling addressed rubber tips for walker feet. Product information and photos
were submitted for our review.
The product under consideration is Walgreens item #586505, Rubber Walker/Commode Tips, or rubber feet
or caps for use with a walker. The feet are constructed of 70 percent styrene-butadiene rubber, 20 percent
natural rubber, and 10 percent catalysts. The rubber is molded, vulcanized, and non-cellular. There is an iron
washer inside each foot to keep the leg of the walker from puncturing the rubber during use. The feet provide
friction and cushioning on surfaces to support stability of the walker. They also prevent scratching and
decrease noise during use. These feet are marketed only for use with walkers and commodes and would not
be used for other purposes.
The applicable subheading for item #586505, Rubber Walker/Commode Tips will be 4016.99.6050,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of vulcanized
rubber other than hard rubber: other: other: other: other: other: other. The general rate of duty will be 2.5
percent ad valorem.
Both walkers and commodes have been recognized within Customs’ ruling history as being subject to duty
free treatment under subheading 9817.00.96, HTSUS, also known as the Nairobi Protocol (See New York
Ruling Letter N330412, dated February 8, 2023, and Headquarters Ruling Letter 557734, dated April 18,
1994). The feet are dedicated for use with either item and are designed and marketed for such use. It is
unlikely that the feet would be purchased for any other use. The walker or commode would be unstable
without the feet. Accordingly, we find that the walker/commode feet are eligible for duty-free treatment
under 9817.00.96, 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 Christina Allen at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division