The tariff classification of dental orthodontic wire-bending machines from China.

N358675
March 5, 2026
CLA-2:OT:RR:NC:N3:143
CATEGORY: Classification
TARIFF NO.:9018.49.8080
ZHIHUA NIE Shanghai Zhende Dental Technology Co., Ltd. 053, 1st Floor, Building 5, No. 786 Wangqiao Road; No. 396 Yuntong Road; No. 729 Jingye Road; No. 66 Lizhi Road; Pudong New Area Shanghai 200120 China RE: The tariff classification of dental orthodontic wire-bending machines from China. Dear Ms. Nie: In your letter dated February 10, 2026, you requested a tariff classification ruling. The items under consideration, the Bender S, Bender Max, and Bender-L, are specialized machines designed to bend medical-grade stainless steel wires into prescribed shapes for various orthodontic appliance components, including retainers, labial bows, lingual arches, transpalatal arches, Nance arches and claps. The Bender S and Bender-L models are labeled with the trade name “Denck Ortho,” while the Bender-L bears the label “OG-DOS Bender-L.” The Bender S is designed to process medical-grade short straight orthodontic wires. The Bender Max is intended to process medical-grade spool wires and incorporates a multi-wheel system to straighten the wire prior to bending. The Bender-L is specifically designed for medical-grade twisted orthodontic wires with a diameter of 0.5 mm. All three machines operate by receiving orthodontic wire design data from proprietary software, which uses dental 3D tooth models to generate wire geometries tailored to specific dental appliance designs. These machines are physically limited to feeding and bending medical-grade orthodontic wires with diameters below 1 mm. They are intended exclusively for use by dental orthodontic laboratories and dental professionals, and are marketed and sold solely through dental and orthodontic industry channels. They are not intended or suitable for general industry, manufacturing, or non-dental applications. The applicable subheading for the Bender S, Bender Max, and Bender-L will be 9018.49.8080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: Other instruments and appliances, used in dental sciences, and parts and accessories thereof: Other: Other.” The general rate of duty will be free.

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 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 Dionisia Melman at [email protected].
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division