CLA-2-84:OT:RR:NC:N2:212
Marc Jiona
Humanware
1800 rue Jean-Berchmans-Michaud
Drummondville, QC J2C7G7
Canada
RE: The tariff classification of parts and accessories for a braille eReader from China
Dear Mr. Jiona:
In your letter dated March 27, 2026, you requested a tariff classification ruling.
There are four items at issue with this request, which you state are all specifically designed as parts or
accessories for the HumanWare Braille eReader. The first item under consideration is identified by part
number MECO-0278 and further described as field replaceable individual braille cells. The subject cells are
replacement braille keys with tactile buttons and an attached printed circuit board assembly (PCBA). The
keys are specifically designed for incorporation within the Braille eReader, a device designed to allow for a
visually impaired person to read and interact with books and other documents in a paperless environment.
In your request, you suggest that the correct classification for the subject braille cells is 8473.30.5100,
Harmonized Tariff Schedule of the United States (HTSUS). As the finished device is considered an
Automatic Data Processing (ADP) machine of heading 8471, HTSUS, and the subject cells meet the
definition of parts, we agree.
The second item at issue is identified by part number PAS10047 and further described as replacement
Perkins keys. These keys are the input devices for the braille reader and emulate tactile braille dots that form
braille characters. The Perkins keys are specifically designed for incorporation within the eReader and can be
used for no other function.
In your request, you suggest that the correct classification for the Perkins keys is 8536.50.9033, HTSUS,
which provides for “Other Switches”. We disagree. The item in question employs no electrical switching
functionality and simply serves as a tactile interface, which allows the user to operate the HumanWare
e-Reader. We find that the keyboard keys are specifically designed for and can only be used in the
HumanWare e-Reader, which is properly classified in 8471. Once the key is installed, it is integral to the
function of the article, thus meeting the definition of a part for classification purposes, and is more accurately
classified in 8473, HTSUS.
The third item at issue is identified by part number PCBA-0099WCO and described as the main PCBA for
the eReader. This board is a fully populated printed circuit board, which you state functions as the main
control board within the eReader. The device manages the cell output, navigation, and operating system
accessibility. The device is specifically designed for incorporation within the eReader.
In your request, you suggest that the correct classification for the PCBA will be 8473.30.1180, HTSUS. We
agree.
The final item is identified by part number EQUI-0032 and described as the Braille USB LCD Adaptor. This
device is comprised of a small LCD screen within a plastic enclosure. You state that the adaptor is a
dedicated electronic interface enabling a visual display of information being relayed to the eReader. This
allows another user, such as a friend or teacher, to assist the visually impaired person with the information on
the reader. You state that this device can only be used in conjunction with the HumanWare eReader.
In your submission, you suggested that the subject USB LCD Adaptor is classified in subheading
8528.59.3500, HTSUS, which provides for “Monitors and Projectors, …: Other: Color: With a flat panel
screen: Color: Other: Incorporating video recording or reproducing apparatus: With a video display diagonal
not exceeding 34.29 cm.” However, this LCD adapter is not a monitor of heading 8528, HTS. Therefore,
classification in this subheading is not applicable. Additionally, as the device is used only in conjunction with
the eReader and is not more specifically provided for in another heading, it is considered an accessory.
The applicable subheading for the braille cells, part number MECO-0278, the Perkins keys, part number
PAS10047, and the Braille USB LCD Adaptor, part number EQUI-0032, and will be 8473.30.5100, HTSUS,
which provides for “Parts and accessories (other than covers, carrying cases and the like) suitable for use
solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of
heading 8471: Not incorporating a cathode ray tube: Other.” The general rate of duty will be Free.
The applicable subheading for the PCBA-0099WCO will be 8473.30.1180, HTSUS, which provides for
"Parts and accessories … suitable for use solely or principally with machines of headings 8469 to 8472: Parts
and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Printed circuit
assemblies". The general rate of duty will be Free.
In your submission, you further suggest that the four articles described above should be granted treatment
under the secondary classification 9817.00.96, HTSUS, which applies to articles and parts and accessories of
articles specifically designed or adapted for the use or benefit of the permanently or chronically physically or
mentally handicapped.
Subheading 9817.00.96, HTSUS, covers: “Articles specially designed or adapted for the use or benefit of the
blind or other physically or mentally handicapped persons; parts and accessories (except parts and
accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the
foregoing articles . . . Other.” The term “blind or other physically or mentally handicapped persons” includes
“any person suffering from a permanent or chronic physical or mental impairment which substantially limits
one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing,
hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS.
Subheading 9817.00.96, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles,
dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic
articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS.
In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308
(Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent
greater than in other cases or towards others” and “designed” means something that is “done, performed, or
made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We
must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then,
whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314. The Court of Appeals
for the Federal Circuit (CAFC) clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially designed,” the
merchandise “must be intended for the use or benefit of a specific class of persons to an extent greater than
for the use or benefit of others” and adopted the five factors used by U.S. Customs and Border Protection
(CBP):
(1) the physical properties of the article itself (i.e., whether the article is easily distinguishable by
properties of the design, form, and the corresponding use specific to this unique design, from articles
useful to non-handicapped persons); (2) whether any characteristics are present that create a
substantial probability of use by the chronically handicapped so that the article is easily
distinguishable from articles useful to the general public and any use thereof by the general public is
so improbable that it would be fugitive; (3) whether articles are imported by manufacturers or
distributors recognized or proven to be involved in this class or kind of articles for the handicapped;
(4) whether the articles are sold in specialty stores which serve handicapped individuals; and, (5)
whether the condition of the articles at the time of importation indicates that these articles are for the
handicapped.
Based upon the information provided, the finished HumanWare eReader would satisfy the five factors set
forth above as it is clearly primarily used by those suffering from blindness. Further, the devices described
above are specifically designed as parts and, in the case of the adaptor, accessories only suitable for use with
the eReader and could serve no other function on their own. As such, the braille cells, Perkins keys, PCBA,
and adaptor would be eligible for secondary classification under 9817.00.96, HTSUS.
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 Luke LePage at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division