The tariff classification of a Disposable Adhesive Syringe from China

N347496
April 18, 2025
CLA-2-82:OT:RR:NC:N1:118
CATEGORY: Classification
TARIFF NO.: 8205.59.5560; 9903.01.24; 9903.01.63; 9903.88.03
Lance Crain Crain Cutter Co., Inc. 1155 Wrigley Way Milpitas, CA 95035 RE: The tariff classification of a Disposable Adhesive Syringe from China Dear Mr. Crain: In your letter dated April 4, 2025, you requested a tariff classification ruling. The imported item, Part No. 0143-0013, is described as a Disposable Adhesive Syringe. The device is used for repairing bubbles in glued-down flooring materials, such as carpet and vinyl. You have stated that it incorporates a 2.677 inch long stainless-steel syringe that is connected to a polypropylene barrel and plunger with a rubber stopper. The total capacity of the barrel is 2 ounces. The syringe can deliver adhesive to problem spots in floors, leaving a minimal puncture mark after application. The applicable subheading for the Disposable Adhesive Syringe, Part No. 0143-0013, will be 8205.59.5560, Harmonized Tariff Schedule of the United States (HTSUS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other: other: of iron or steel: other: other (including parts). The general rate of duty will be 5.3% ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 8205.59.5560, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong

and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. ?Products from all other countries will be subject to an additional 10 percent ad valorem rate of duty. ?At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63, in addition to subheading 8205.59.5560, HTSUS, listed above.? Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8205.59.5560, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8205.59.5560, HTSUS, listed above. 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/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Anthony Grossi at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division