CLA-2-84:OT:RR:NC:N1:105
Samantha Summey
Draeger Medical Systems, Inc.
3135 Quarry Rd
Telford, PA 18969
RE: The tariff classification of a disposable CLIC absorber from Germany
Dear Ms. Summey:
In your letter dated March 19, 2026, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The items under consideration are described as disposable CLIC absorbers, which are devices designed for
use with Dräger anesthesia workstations and compatible respiratory therapy equipment. The absorbers are
sealed plastic cartridges containing a carbon dioxide absorbent material (typically soda lime or equivalent
chemical compound). During anesthesia or respiratory therapy, the patient’s exhaled gases pass through the
absorber. The absorbent material chemically removes carbon dioxide from the gas mixture, allowing the
remaining gases to be recirculated safely to the patient. The CLIC absorber is designed to fit Dräger
anesthesia systems using the proprietary CLIC mounting interface. Each model number (MX0004,
MX50004, MX50100, MX50120, MX00001, and MX50050) operates in a similar way but contains a slightly
different shape that works with different machines.
You proposed classification under subheading 9019.20.00, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other
therapeutic respiration apparatus; parts and accessories thereof.” The intended function of the subject CLIC
absorbers are to remove carbon dioxide from exhaled gases. Chapter 90 Note 2 (a) states “that parts and
accessories which are goods included in any of the headings of this chapter or of chapter 84, 85 or 91 (other
than heading 8487, 8548 or 9033), are in all cases to be classified in their respective headings.” Since the
CLIC absorber is a filtering device of heading 8421, it is excluded from classification in chapter 90.
Accordingly, the applicable subheading for the disposable CLIC absorber will be 8421.39.0190, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers;
filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying
machinery and apparatus for gases: Other: Other: 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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division