The tariff classification of components for a circumcision clamp from Taiwan and the United States

N077476 October 19, 2009 CLA-2-CLA:OT:RR:NC:N4:405 CATEGORY: Classification TARIFF NO.: 9018.90.8000 Donna Kjeldsen Centurion Medical Products301 Catrell Drive Howell, MI 48843 RE: The tariff classification of components for a circumcision clamp from Taiwan and the United States Dear Ms. Kjeldsen: In your letter dated September 25, 2009, you requested a tariff classification ruling. In your submission you describe several components which, when assembled, form the Centurion Circlamp, a clamp used in the procedure of male circumcision. The Circlamp is similar in design and appearance to a Gomco clamp. Your submission describes three main components. The first is the Circlamp Clamp Arm, which is manufactured in the United States. The Clamp Arm is combined with the Centurion 1.6 cm Ball Bell, and a “Thumb Screw with Integrated Washer” (both manufactured in Taiwan) to form the completed product. The Clamp Arm is made from chrome plated zinc, while the Ball Bell and Thumb Screw are both made of chrome plated brass. The imported components are both engraved with the Centurion logo, and are clearly designed to be used for the Circlamp, and are not suitable for any other use.The imported components and domestically produced Clamp Arm are assembled into the finished product here in the United States. According to the Centurion Medical Products catalog, found on your website, the Centurion Circlamp is available for purchase individually, or as part of a single-use custom circumcision tray. The Circlamp is designed to be used once, and then disposed of. Separately imported parts, if identifiable as suitable for use solely or principally as parts of this kind of device (see General Harmonized System Explanatory Note III to Chapter 90) or of this particular item (see Headquarters Ruling Letter 965546, 8-2-02), are classified in its heading if not excluded from HTSUS Chapter 90 by its Note 2-a or 1 or by HTSUS Add. US Rule of Interpretation 1-c (see HRLs 965968, 12-16-02, and 967233, 2-18-05). None of those exclusions appear to apply to the components here when separately imported. The applicable subheading for the Centurion Circlamp and its components will be 9018.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "other" instruments and apparatus used in medical, surgical, dental, or veterinary sciences, 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