The tariff classification of a treatment table from China

N305511 August 9, 2019 CLA-2-94:OT:RR:NC:N3:135 CATEGORY: Classification TARIFF NO.: 9402.90.0020 Mr. David M Spooner Barnes & Thornburg LLP 1717 Pennsylvania Ave. NW, Suite 500 Washington, DC 20006 RE: The tariff classification of a treatment table from China Dear Mr. Spooner: In your letter dated July 29, 2019, you requested a tariff classification ruling on behalf of Earthlite, LLC. Pictures, marketing material, product specifications, and sale information were submitted for our review. Ellora™ Electric Lift Treatment Table is advertised as a versatile, ADA compliant, electric height adjustable table for therapeutic massage, physical therapy, chiro, and various wellness treatments. It features a steel frame, an actuator, a three-layer cushioning system, polyurethane upholstery, a foot control, and wheels. The table is presented in three forms: Flat, Tilt (back), and Salon (denoting both back and leg tilt options on the table) and measures 28, 30, or 32 inches in width, 73 inches in length, and 18 to 37 inches in adjustable height. The recommended lift capacity is 600 pounds. You state while sold separately, the vast majority of the tables are sold with the Deluxe Adjustable™, Flex-rest™, and Caress™ self-adjusting face-rest platforms and the accompanying cushion. At the time of importation, the treatment tables may be entered assembled or unassembled. According to the submission, the predominant sales of the treatment tables are to massage therapists, physical therapists, chiropractors, acupuncturists, and medical facilities for massage treatment. You also distinguish massage treatment tables such as the Ellora from facial and waxing tables. For example, the treatment tables are wider, have face holes and/or face cradle slots, and can handle much heavier weight loads, often twice the weight or more of a typical client. The applicable subheading for the Ellora™ Electric Lift Treatment Table in three forms, whether entered assembled or unassembled at the time of importation, will be 9402.90.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[m]edical, surgical, dental or veterinary furniture (for example, operating tables, examination tables, hospital beds with mechanical fittings, dentists' chairs); barbers' chairs and similar chairs, having rotating as well as both reclining and elevating movements; parts of the foregoing articles: [o]ther: [o]ther.” The general 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 the World Wide Web at https://hts.usitc.gov/current. 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 Fei Chen at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division