The tariff classification of PVC support straps used as part of an orthopedic appliance, from Taiwan.

N059148 May 14, 2009 CLA-2-90 :OT:RR:NC:N4:405 CATEGORY: Classification TARIFF NO.: 9021.10.0090 Martin L. Marin American Shipping Company 400 Oceangate, Suite 1106 Long Beach, CA 90802 RE: The tariff classification of PVC support straps used as part of an orthopedic appliance, from Taiwan. Dear Mr. Martin: In your letter dated April 28, 2009, you requested a tariff classification ruling on behalf of Enventys, LLC. Samples were provided The samples provided with your ruling request consist of a number of PVC straps of varying lengths and widths, all of which are backed with hook and loop fastener strips. It should be noted that the straps, while very flexible, do not stretch to any significant degree. Based on the information you presented, the PVC straps are part of an item known as the “SaeboStretch”, which is marketed as a type of hand splint for individuals who have suffered a neurological injury, such as a stroke. The PVC straps are specially designed to wrap around an individual’s hand and wrist, fastening it to a proprietary hand piece to create the splint. The “SaeboStretch” splint is designed to prevent joint damage to the hand and wrist, while improving and maintaining range of motion (per “SaeboStretch’s” promotional material). A sample of the proprietary hand piece was not included with the request. The straps do appear to be designed specifically for use in conjunction with the hand piece. They are fashioned in an assortment of lengths and widths, and their application depends on what part of the hand they will be wrapped around. The longer PVC straps appear to be designed to fasten the hand piece to the wrist and palm, while the shorter, thin straps can be used to immobilize individual fingers. Without the complementary presence of the hand piece, the straps themselves would serve no obvious purpose. We agree that the applicable subheading for the PVC support straps will be 9021.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other” Orthopedic or fracture appliances, and parts and accessories thereof. 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 on World Wide Web at http://www.usitc.gov/tata/hts/. 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 J. Sheridan at (646) 733-3012. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division