CLA-2-90:OT:RR:NC:N3 135
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive , Peabody, MA 01960
RE: The tariff classification of catheter sub-assemblies from China
Dear Ms. Murrin:
In your letter dated September 16, 2024, you requested a tariff classification ruling on behalf of Genesis Vascular Interventions MedTech (Wuxi) Co., Ltd. Additional information was submitted by email dated September 18 and September 19, 2024.
SA, Neuron Max 088 is a sub-assembly for a delivery catheter. It consists of a handle, a strain relief component, and tubing composed of three layers: an inner layer of polytetrafluoroethylene (PTFE), a middle layers of woven stainless steel, and an outer layer of nylon and polymer material. After importation, the sub-assembly will undergo tip forming, adding on an ID band, and hydrophilic coating to form a delivery catheter. The catheter will be matched/attached with a hemostasis valve adapter, and then packed with a dilator and hemostasis valves with Y-adapters and sterilized.
SA, 044 Coronary Aspiration Catheter Distal Shaft and SA, 044 Coronary Aspiration Catheter Hypotube are the primary sub-assemblies of a coronary aspiration catheter, which also include a guidewire lumen. The SA, 044 Coronary Aspiration Catheter Distal Shaft is a tube with complete lumen and a mark band made of platinum-iridium alloys. The shaft has an inner layer of PTFE, a middle layer of nitinol, and an outer layer of polymer material. You explain that the complete lumen is used for keeping negative pressure during a procedure and the mark band (a circle ring), which can be seen at x-ray, is used for showing the position of the catheter tip in procedure. The SA, 044 Coronary Aspiration Catheter Hypotube consists of a handle, a strain relief component, a double mark band, a single mark band (the mark bands are printed by ink), and a Hypotube composed of an inner layer of stainless steel, and outer layer of pebax (polyether block polyamide) and nylon. After importation, the two sub-assembles are laminated together by hot melting by heating. The further processing includes guidewire lumen lamination, tip forming, hydrophilic coating, packing, and sterilization.
The applicable subheading for the SA, Neuron Max 088 Catheter Sub-assembly, SA, 044 Coronary Aspiration Catheter Distal Shaft, and SA, 044 Coronary Aspiration Catheter Hypotube will be 9018.39.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for [i]nstruments 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: [s]yringes, needles, catheters, cannulae and the like; parts and accessories thereof: [o]ther: [b]ougies, catheters, drains and sondes, and parts and accessories thereof: [o]ther. The rate of duty will be free.
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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division