The tariff classification of a body cooling system from China

N175755 August 15, 2011 CLA-2-84:OT:RR:NC:N1:106 CATEGORY: Classification TARIFF NO.: 8419.89.9540 Lois Sproul, President Lois Sproul CHB, Inc. 510 Plaza Drive, Suite 2250 College Park, GA 30349 RE: The tariff classification of a body cooling system from China Dear Ms. Sproul: In your letter dated July 19, 2011 you requested a tariff classification ruling on behalf of your client, EMS Innovations, Inc. of Pasadena, MD. You included descriptive literature with your request. The merchandise under consideration has been identified as the Interchangeable Cooling Environment (ICE) System and the attachments for the unit. The ICE unit is designed to reduce the body's core temperature by providing heat removal from numerous areas of the body. The system effects a heat transfer between the patient’s body and chilled water circulated through tubing on special garments he or she is wearing. The system can be used by workers on such "hot job" applications as handling hazardous materials, as an intervention device to cool down a patient who has suffered cardiac arrest or stroke, or as a temporary preserving system in mortuary situations.The system is made up of a cooling unit which is basically a box with a water reservoir and a pump; water-supply hose; and a set of garments. The water supply hose attaches to the cooling unit and to fittings on the garments and serves as the conduit for the water between the cooling unit and the garments, which you state are made of PVC. You state, in the included literature, that the ICE system will include the Ice Unit, battery, battery charger, carrying bag, hoses and, depending on the specific package purchased, either the rehabilitation vest, rapid therapeutic cooling wrap, rapid therapeutic cooling cap, therapeutic cooling pad, mortuary cooling pad, or combination of the above. The applicable subheading for the Ice Unit Cooling System will be 8419.89.9540, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other machinery, plant or equipment, designed for cooling, other. The rate of duty will be 4.2%. Your inquiry does not provide enough information for us to give a classification ruling on the individual items if imported separately. If you wish classification of the individual articles your request should include: Sample of the carrying case, in the condition as imported. Please include a material breakdown. Sample of the rehabilitation vest, rapid therapeutic cooling wrap, rapid therapeutic cooling cap, therapeutic cooling pad, mortuary cooling pad, and mortuary cooling pad bag. Please include a material breakdown for each item. Please provide descriptive and technical literature on the chair. A sample is not requested at this time, although you should provide a material breakdown for the chair. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you. 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 Matthew Sullivan at (646) 733-3013. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division