The tariff classification of Kinn Automatic Volume Management System from Canada

N357912
March 4, 2026
CLA-2-90:OT:RR:NC:N3:135
CATEGORY: Classification
TARIFF NO.: 9817.00.96
Alexandra Lind Vessl Prosthetics Inc. 10-100 Collip Circle London Canada RE: The tariff classification of Kinn Automatic Volume Management System from Canada Dear Ms. Lind: In your letter dated January 16, 2026, you requested a tariff classification ruling. Vessl’s Kinn™ Automatic Volume Management System (“Kinn System”) is a prosthetic article designed to be incorporated into a prosthetic socket to enhance the comfort and fit of a prosthetic leg. The system enables patients to have a prosthetic socket that automatically adjusts to their limb. It features both automatic volume adjustment and vertical shock absorption. It comprises a lamination plate, a shock absorber, a main Kinn assembly including a manual dial for tension adjustment and a release button, a lamination dummy plug, a tube, a cable, a cable tool, four screws, and a tension setting tool (indicator). The Kinn System is attached to the distal end of the prosthetic socket via its lamination plate. Its integrated shock absorber mitigates vertical forces and initiates the volume management mechanism through compression. With each step, the shock absorber compresses, converting kinetic energy into mechanical action that drives the volume adjustment mechanism. The volume management system’s manual and automatic tensioning allow for active and passive socket fit optimization. The maximum tension setting can be adjusted per patient preference. By actively managing volume changes, the Kinn System enhances fit, reduces discomfort, and provides a reliable, worry-free prosthetic experience. In your submission you requested consideration of a classification under 9817.00.96, Harmonized Tariff Schedule of the United Sates (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. Subheading 9817.00.96, HTSUS, covers: “Articles 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 . . . Other.” The term “blind or other physically or mentally handicapped persons” includes “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.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS. Subheading 9817.00.96, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles, dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS. In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308 (Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent greater than in other cases or towards others” and “designed” means something that is “done, performed, or made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then, whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314. The Court of Appeals for the Federal Circuit (CAFC) clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially designed,” the merchandise “must be intended for the use or benefit of a specific class of persons to an extent greater than for the use or benefit of others” and adopted the five factors used by U.S. Customs and Border Protection (CBP): (1) the physical properties of the article itself (i.e., whether the article is easily distinguishable by properties of the design, form, and the corresponding use specific to this unique design, from articles useful to non-handicapped persons); (2) whether any characteristics are present that create a substantial probability of use by the chronically handicapped so that the article is easily distinguishable from articles useful to the general public and any use thereof by the general public is so improbable that it would be fugitive; (3) whether articles are imported by manufacturers or distributors recognized or proven to be involved in this class or kind of articles for the handicapped; (4) whether the articles are sold in specialty stores which serve handicapped individuals; and, (5) whether the condition of the articles at the time of importation indicates that these articles are for the handicapped. In this case, the Kinn System is designed for individuals who are amputees and require prostheses for mobility. It provides dynamic management of residual limb volume fluctuations and maintains a stable, secure socket fit. The system enhances patient comfort and improves mobility. Loss of a limb is considered a chronic physical impairment that substantially limits the ability to walk and ambulate, which are major life activities. As an article specially designed or adapted for physically handicapped persons, the Kinn System qualifies for duty-free treatment under subheading 9817.00.96, HTSUS. 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/. 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division