CLA-2-90:OT:RR:NC:N3135
Bryan Latham
Nurse Assist LLC
4409 Haltom Rd
Haltom City, TX 76117
RE: The tariff classification of unassembled I.V. flush syringes from China
Dear Mr. Latham:
In your letter dated January 7, 2026, you requested a tariff classification ruling. Additional information was
provided via email dated January 14 and January 22, 2026.
The products under consideration are unassembled I.V. flush syringes imported as complete kits, typically
packaged in bulk master cartons. Each kit contains all the necessary components for one syringe: a barrel, a
plunger, a grommet (stopper), and a tip cap. After importation, these kits are assembled into complete 12ml
syringes, which are then filled with 0.9 percent saline solution.
Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in
accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be
determined according to the terms of the headings and any relative Section or Chapter Notes. Where goods
cannot be classified solely on the basis of GRI 1 and if the headings and legal notes do not require otherwise,
the remaining GRIs may be applied. We agree with your proposed classification under heading 9018,
HTSUS. However, we disagree with your classification under subheading 9018.39, HTSUS, which covers
"Syringes, needles, catheters, cannulae and the like; parts and accessories thereof: Other: Other." As
unassembled syringes in their imported condition, these products are classified as syringes according to GRI
2(a).
The applicable subheading for the unassembled I.V. flush syringes will be 9018.31.0080, HTSUS, which
provides for “Instruments and appliances used in medical, surgical, dental or veterinary sciences, including
scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories
thereof: Syringes, needles, catheters, cannulae and the like; parts and accessories thereof: Syringes, with or
without needles; parts and accessories thereof: Syringes with or without their needles: Other.” The general
rate of duty will be free.
The 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/.
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 Fei Chen at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division