CLA-2-94:OT:RR:NC:N4:463
Adam Gustafson
STERIS
5960 Heisley Rd.
Mentor, OH 44060
RE: The tariff classification of an adjustable workstation from Mexico
Dear Mr. Gustafson:
This ruling is being issued in response to your letter dated December 10, 2024, requesting a tariff classification determination for a height-adjustable workstation. In lieu of a sample, pictures, product descriptions and a website URL were provided.
The article is identified as the AMSCO Prep & Pack Table and is described as a workstation for organizing surgical instruments.
The AMSCO Prep & Pack Table is equipped with a stainless-steel surface and casters. The table is constructed of steel and extruded aluminum and is capable of handling evenly distributed loads of up to 500 lbs. The tabletop height can be adjusted from 24.4" to 42.5". It comes with either a manual height adjustment or an electronic height adjustment. Additionally, there is an available back-to-back configuration, and the deluxe tables include a light, whiteboard, monitor arm, CPU holder and blue Akro bins. The workstation SKU numbers and model names are listed below:
SKU
NAME
PREP55
AMSCO PREP & PACK TABLE DELUXE ELECTRIC 36 x 72
PREP56
AMSCO PREP & PACK TABLE STANDARD ULTRA FRAME SINGLE 36 x 72
PREP57
AMSCO PREP & PACK TABLE DELUXE ULTRA FRAME SINGLE 36 x 72
PREP58
AMSCO PREP & PACK TABLE STANDARD MANUAL ADJUST DOUBLE 36 x 72
PREP59
AMSCO PREP & PACK TABLE DELUXE MANUAL ADJUST DOUBLE 36 x 72
PREP61
AMSCO PREP & PACK TABLE DELUXE ELECTRIC DOUBLE 36 x 72
PREP63
AMSCO PREP & PACK TABLE DELUXE ELECTRIC 30 X 60
The workstation is made in Mexico. See image of a representative workstation below:
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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 of the tariff schedule and any relative section or chapter notes. If the goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order.
In understanding the language of the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity Description and Coding System, which constitutes the official interpretation of the Harmonized System at the international level, may be utilized. The ENs, although not dispositive or legally binding, provide a commentary on the scope of each heading and are generally indicative of the proper interpretation of the HTSUS. The ENs to Chapter 94 of the HTSUS state, in relevant part, for the purposes of this Chapter, that the term “furniture” means: (A): Any “movable” articles (not included under other more specific headings of the Nomenclature), which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings, hotels, theatres, cinemas, offices, churches, schools, cafés, restaurants, laboratories, hospitals, dentists, surgeries, etc., or ships, aircraft, railway coaches, motor vehicles, caravan-trailers or similar means of transport. (It should be noted that, for purposes of this Chapter, articles are considered to be “movable” furniture even if they are designed for bolting, etc., to the floor, e.g., chairs for use on ships). Similar articles (seats, chairs, etc.) for use in gardens, squares, promenades, etc., are included in this category. This workstation meets this definition of furniture.
The AMSCO Prep & Pack Table is a type of table and, barring significant evidence to the contrary, U.S. Customs and Border Protection (CBP) has historically found that the material comprising the tabletop imparts the essential character to a table. (See NYRLs N315828 and N334127.) This workstation is no exception.
You suggest that this article does not meet the definition of medical furniture in Heading 9402, HTSUS, and that, therefore, it should be classified in Heading 9403, HTSUS, specifically in subheading 9403.20.0090, HTSUS. We agree. The applicable classification for the AMSCO Prep & Pack Table with SKU numbers PREP55, PREP56, PREP57, PREP58, PREP59, PREP61 and PREP63 will be subheading 9403.20.0090, HTSUS, which provides for “Other furniture and parts thereof: Other metal furniture: Other: Other.” The general 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 on the internet at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is 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. If the facts are modified in any way, or if the goods do not conform to these facts at the time of importation, you should bring this to the attention of 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 Title 19 of the Code of Federal Regulations (19 C.F.R. Part 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, contact National Import Specialist Seth Mazze at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division