The tariff classification of a rollator from China

N353759
October 3, 2025
CLA-2-90:OT:RR:NC:N3:135
CATEGORY: Classification
TARIFF NO.: 9021.10.0090; 9817.00.96
Michael Gamble Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The tariff classification of a rollator from China Dear Mr. Gamble: In your letter dated September 15, 2025, you requested a tariff classification ruling on behalf of your client, Walgreen Company. The rollator (WIC 737725) is a foldable, lightweight, and durable mobility aid designed for both indoor and outdoor use, providing support and independence for individuals needing walking assistance. It features adjustable handles for a customized fit, handbrakes for safety, a padded seat with a curved backrest, and a convenient under-seat storage bag for personal items. This rollator has a maximum weight capacity of 350 pounds. The applicable subheading for the rollator will be 9021.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]rthopedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability; parts and accessories thereof: [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 of China, Hong

Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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. However, the additional duties imposed by headings 9903.01.24 and 9903.01.25 shall not apply to goods for which entry is properly claimed under a provision of chapter 98 of the tariff schedule pursuant to applicable regulations of U.S. Customs and Border Protection (“CBP”), and whenever CBP agrees that entry under such a provision is appropriate, except for goods entered under heading 9802.00.80; and subheadings 9802.00.40, 9802.00.50, and 9802.00.60. In your submission, you requested consideration of a secondary classification under subheading 9817.00.96, HTSUS, which applies to articles and parts and accessories of articles specifically designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped. Customs and Border Protection has previously ruled that similar rollators and walkers are eligible for subheading 9817.00.96, HTSUS. See Headquarter ruling 561117 (November 16, 1998), NY rulings N235453 (December 12, 2012), and N325579 (May 5, 2022). Accordingly, a secondary classification will apply for the rollator 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division