CBP Ruling N301937 — The tariff classification on lens cleaning devices from China.

Tariff classification

Headings: 9603

GRI rules applied: GRI 3(b)

Product description

The products under consideration are described as “Carbonklean Peeps,” “Lens Pen,” and “Laptop-Pro.” The “Lens Pen” comes in three versions, “FilterKlear,” MicroPro,” and “MiniPro.” Each of these devices contains a cleaning pad on one end and a brush on the other end. The brushes are made of natural goat hair bristles and are retractable, which protects them from contamination when not in use. These products are primarily designed to clean optical lenses, such as eyeglasses, camera lenses, and binoculars, while protecting their anti-reflective coating from potential damage caused by abrasive particles during the cleaning process. It is in this office’s opinion that the brushes impart the essential character to these products, General Rule of Interpretation 3(b) noted.

CBP rationale

The applicable subheading for these lens cleaning devices will be 9603.90.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.

Full text

N301937 December 19, 2018 CLA-2-96:OT:RR:NC:N4:415 CATEGORY: Classification TARIFF NO.: 9603.90.8050 Ms. Jennifer Diaz Diaz Trade Law 12700 Biscayne Boulevard, Suite 301 North Miami, FL 33181 RE: The tariff classification on lens cleaning devices from China. Dear Ms. Diaz: In your letter dated November 26, 2018, you requested a tariff classification ruling on behalf of your client Parkside Optical, Inc. Samples were submitted and will be returned separately. The products under consideration are described as “Carbonklean Peeps,” “Lens Pen,” and “Laptop-Pro.” The “Lens Pen” comes in three versions, “FilterKlear,” MicroPro,” and “MiniPro.” Each of these devices contains a cleaning pad on one end and a brush on the other end. The brushes are made of natural goat hair bristles and are retractable, which protects them from contamination when not in use. These products are primarily designed to clean optical lenses, such as eyeglasses, camera lenses, and binoculars, while protecting their anti-reflective coating from potential damage caused by abrasive particles during the cleaning process. It is in this office’s opinion that the brushes impart the essential character to these products, General Rule of Interpretation 3(b) noted. The applicable subheading for these lens cleaning devices will be 9603.90.8050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 2.8% ad valorem. 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 at https://hts.usitc.gov/current. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Kristopher Burton at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division

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