CLA-2-30:RR:NC:2:238 C82916
Mr. Marty Langtry
Tower Group International
2400 Marine Avenue
Redondo Beach, CA 90278-1103
RE: The tariff classification of HOLD from Taiwan
Dear Mr. Langtry:
In your letter dated December 18, 1997, on behalf of your client, William J. Wade, you requested a tariff classification ruling.
The subject product, designated by the acronym, "HOLD " (Hemostatic/Occlusive Leverage Device), is a pressure dressing designed to apply pressure (compression) to the groin area following procedures which mandate femoral arterial or venous puncture (e.g., cardiac cathetization, coronary arteriography, electrophysiologic study, etc.). After initial hemostasis at the puncture site is obtained (by direct manual pressure), the HOLD dressing is applied, resulting in prolonged application of greater direct pressure to either the femoral artery or vein. Use of the HOLD dressing is said to obviate the need for extensive skin preparation, shaving, bulky adhesive dressings, and sand bags. You state that the product will be put up, packed one to a bag, for retail sale.
The submitted sample consists of two components: a waistband and a groin strap, both of which are elasticized and adjustable. The waistband has a detachable styrofoam disc, measuring approximately 3" in diameter, fastened to its inside surface with Velcro . It is secured around the patient's waist by a Velcro closure. The groin strap has three pieces of Velcro sewn on it, one to attach it to the waistband, and the other two serving as a closure to hold it around the hip and upper thigh. After initial hemostasis has been achieved, the disc is positioned directly over the puncture site, and the groin strap is attached to the waistband (directly over the disc). The strap is then wrapped around the hip and thigh, and self-fastened. (Tighter adjustment of the groin strap results in an increase in the pressure applied to the puncture site).
The applicable subheading for the subject product will be 3005.90.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for: "Wadding, gauze, bandages and similar articles (for example, dressings, adhesive plasters, poultices), impregnated or coated with pharmaceutical substances or put up in forms or packings for retail sale for medical, surgical, dental or veterinary purposes: Other: Other: Other." The rate of duty will be free.
This merchandise may be subject to the requirements of the Federal Food, Drug, and Cosmetic Act, which is administered by the U.S. Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number (301) 443-6553.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Cornelius Reilly at 212-466-5770.
Sincerely,
Robert B. Swierupski
Director, National Commodity
Specialist Division