The tariff classification of Magnetic Loop AFO Straps from China

N348803
June 6, 2025
CLA-2-90:OT:RR:NC:N3135
CATEGORY: Classification
TARIFF NO.: 9021.10.0090; 9903.01.24; 9903.01.25
Michael Springman Thrive Orthopedics 387 Ridge Point Drive Carmel, IN 46032 RE: The tariff classification of Magnetic Loop AFO Straps from China Dear Mr. Springman: In your letter dated May 8, 2025, you requested a tariff classification ruling. The products under consideration are two versions of Thrive Orthopedics’ F-Series Magnetic Loop AFO Straps: Thrive Magnetic Loop Strap 1.5 inch (SKU number MSU-1.5) and Thrive Magnetic Loop Strap 1.0 inch (SKU number MSU-1.0). They are the same in design and function. The difference lies in their intended placement: one is designed to wrap around the top of the Ankle Foot Orthosis (AFO) Brace at the calf, where the leg is wider, while the other is intended to secure around the lower shin, where the leg is narrower. They are said to be prefabricated medical-grade strapping systems designed to interface with lower-limb orthoses. These straps have a hook and loop feature and integrate ergonomic finger loops and auto-aligning magnetic closures, allowing users with limited manual strength or dexterity to independently don and doff their AFOs. They are marketed directly to the orthotic and prosthetic clinical sector, including certified orthotists and rehabilitation specialists, to be assembled into the AFO Braces. Your website recommends that a pair of 1.5-inch and 1-inch width straps are for F3 Anterior AFO brace and a pair of 1.5-inch width straps are for F5 Spiral Ankle AFO brace. The applicable subheading for the F-Series Magnetic Loop AFO Straps will be 9021.10.0090, HTSUS, which provides for “[o]rthopedic appliances …: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther.” The general rate of duty will be free. 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 9021.10.0090, 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. At this time products from all 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. 9903.01.25, in addition to subheading 9021.10.0090, HTSUS, listed above. In your submission you requested consideration of a secondary classification under 9817.00.96, HTSUS, which covers: “[a]rticles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing articles: [o]ther.” The F-Series Magnetic Loop AFO Straps are an integral part of the braces and dedicated principally for use with the AFO braces. The plain text language of subheading 9817.00.96 specially excludes parts and accessories of braces from this subheading. As such, the F-Series Magnetic Loop AFO Straps are not eligible for duty-free treatment under subheading 9817.00.96, HTSUS. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Fei Chen at [email protected].
Sincerely,
(for) Steven A. Mack Director National Commodity Specialist Division