The tariff classification of a plastic dust cap from China.

N357882
February 9, 2026
CLA-2-39:OT:RR:NC:N4:415
CATEGORY: Classification
TARIFF NO.: 3926.90.9989; 9817.00.96
David A. Robeson Mohawk Global Logistics 123 Air Cargo Road North Syracuse, NY 13212 RE: The tariff classification of a plastic dust cap from China. Dear Mr. Robeson: In your letter dated January 16, 2026, you requested a tariff classification ruling on behalf of your client, Caire, Inc. Images were provided in lieu of a sample. The product under consideration is described as a dust cap, part 15075347. It is made of acetal plastic, has a cylindrical shape, a diameter of about 0.75 inches, and is about 1.4 inches in length. The cap has a 12-inch beaded stainless-steel chain connected to it and contains an O-ring that seals the quick disconnect valve (QDV) on the Liberator Liquid Oxygen Reservoir. A ring is fastened to the dust cap on one end and is connected to the reservoir by a clamp on the other end making it removable. The dust cap is intended to prevent the QDV from getting dirty and protect it from dust and debris. Your submission indicates that this component is specially designed to fit the Liberator reservoir, has no other known use, and is proprietary to your client. In your request, you suggested that this dust cap should be classified under subheading 9019.20.0000, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. As noted in New York ruling letter (NY) N351475, dated August 12, 2025, U.S. Customs and Border Protection (CBP) determined that the primary function of Caire’s Liberator Liquid Oxygen Reservoir is to store and supply liquid oxygen, which is then used to fill portable units for patient use. CBP concluded that this oxygen reservoir is not classifiable under heading 9019 as an oxygen therapy apparatus, but rather as a container for compressed or liquefied gas under a different heading. Consequently, components such as the dust cap are excluded from classification under subheading 9019.20 as proposed. This dust cap is appropriately classified within chapter 39 as it is made primarily of plastic. Please note that after the issuance of Jing Mei Automotive (USA) v. United States, 682 F. Supp. 3d 1354 (Ct. Int’l Trade

2023), “stoppers, lids, caps and other closures” of subheading 3923.50.0000, HTSUS, must be closures for use with some type of container or similar article used for packing, supporting, or conveyance of goods only. The instant dust cap is for use with a stationary oxygen reservoir that sits stationary in a home environment to store and supply supplemental oxygen to patients. Therefore, it is appropriately classified under heading 3926. As this dust cap, part 15075347, would be considered an article of plastic, and as it is not more specifically provided for elsewhere, the applicable subheading will be 3926.90.9989, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem. In your request, you indicate that you believe this dust cap qualifies for the secondary classification of 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.” Chapter 98, Subchapter XVII, U.S. Note 4(a), HTSUS, defines the term blind or other physically or mentally handicapped persons as including “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working.” In T.D. 92-77, dated August 3, 1992 (26 Cust. Bull. 35, dated August 26, 1992), CBP set forth its position regarding certain issues arising under the Nairobi Protocol. The first issue concerned the interpretation of the term specially designed or adapted. CBP pointed out that a primary factor to be considered in determining whether an article was specially designed and adapted was whether the article was easily distinguishable, by properties of the design and the corresponding use specific to this unique design, from articles useful to non-handicapped individuals. Therefore, if an article is solely dedicated for use by the handicapped it is CBP’s position that this would be conclusive evidence that the article is specially designed or adapted for the handicapped for purposes of the Nairobi Protocol. In NY N351475, the Liberator Liquid Oxygen Reservoir was determined to be specifically designed for use by handicapped individuals with a permanent or chronic heart, lung, or other respiratory disease. The three parts included in that ruling also qualified for duty-free treatment under 9817.00.96, HTSUS. Similarly, it is the opinion of this office that the subject dust cap would be considered an accessory, which would satisfy the description set forth in Chapter 98, Subchapter XVII, U.S. Note 4(a). Thus, we agree that a secondary classification would apply to the dust cap, part 15075347, under 9817.00.96, HTSUS, and will be free of duty and the Merchandise Processing Fee (MPF) upon importation into the United States. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on

the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 CBP 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,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division