CLA-2-90:OT:RR:NC:N1:105
Kevon Baha
Farda LLC
7969 Purple Sage
San Diego, CA 92127
RE: The tariff classification of a smart medication vial from China
Dear Mr. Baha:
In your letter dated January 22, 2026, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The item under consideration is described as the Farda smart medication vial, which is a portable electronic
device comprising a reusable plastic vial enclosure incorporating various electronic components. These
components include a printed circuit board assembly (PCBA), a rechargeable battery, sensors, and wireless
communication modules. The device is engineered to store solid oral medications, such as tablets or capsules,
and to furnish electronic reminder and monitoring capabilities through the detection and logging of user
access to the vial. It is important to note that the device does not automatically dispense, administer, or
otherwise alter the medication. The primary sensing mechanism is facilitated by a load cell, which detects
relative weight changes upon the removal of medication, and a load cell amplifier that conditions the
resultant signal.
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance
with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be
determined according to the terms of the headings and any relevant section or chapter notes. In the event the
articles cannot be classified solely on the basis of GRI 1, GRIs 2 through 6 may be applied in order, as
appropriate.
The Explanatory Notes (EN) to the HTSUS, while not legally binding, may also be consulted to aid in
classification. The smart medication vial is considered to be a composite good within the meaning of GRI 3.
Goods classifiable under GRI 3(b) shall be classified as if they consisted of a material or component which
gives them their essential character. The Explanatory Note to GRI 3(b)(VIII), states that the factors which
determine essential character will vary between different kinds of goods. It may for example, be determined
by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a
constituent material in relation to the use of the goods. GRI 3(c) states that when the essential character of a
composite good cannot be determined, classification is based on the heading that occurs last in numerical
order among those which equally merit consideration. Inasmuch as no one component imparts the essential
character to the subject composite item, GRI 3(b) does not apply.
It is the opinion of this office that the plastic vial in chapter 39, merits equal consideration to the wireless
communication device in chapter 85, and the load cell in chapter 90. Therefore, classification will be
determined based on the competing heading that occurs last in numerical order. GRI 3(c) noted. This is
consistent with CBP’s determination in New York Ruling Letter N325560, dated May 11, 2022, where an
electronic pill case was classified in Chapter 90 utilizing GRI 3(c).
Accordingly, the applicable subheading for the Farda smart medication vial 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 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 Jason Christie at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division