The tariff classification of parts of surgical devices from Costa Rica.

N360435
April 27, 2026
CLA-2-90:OT:RR:NC:N3:143
CATEGORY: Classification
TARIFF NO.: 9018.90.6000; 9018.90.7580
Gail Cumins Sharretts, Paley, Carter & Blauvelt, P.C. 500 Broad Street New York, NY 10005 RE: The tariff classification of parts of surgical devices from Costa Rica. Dear Ms. Cumins: In your letter dated April 3, 2026, you requested a tariff classification ruling, on behalf of your client, AVNA. The items under consideration are Part No. 3013-4, the “inner sleeve” of the articulation joint; Part No. 3013-6, the circular collar/flange-like part with an extended tab, which you described as “nut”; and Part No. 4210-2, the hollow, bobbin-shaped aluminum part. Part No. 3013-4, and Part No. 3013-6, are stainless-steel parts of the articulation joint in the Signia Stapling System. Manufactured to the precise specifications and tolerances required for surgical instruments, these parts are welded together to form the joint that connects the adapter to the power handle. This articulation joint enables the adapter to articulate and rotate, allowing the system to cut and staple tissue effectively during surgical procedures. Part No. 4210-2 is a hollow, bobbin-shaped aluminum component part that functions as the interface joint between the shaft and actuator handle of the Ligasure XP Jaw Sealer/Divider. It enables 360 degrees rotation of the shaft, allowing for precise positioning of the surgical jaws during procedures. This part is one of two components in a two-part assembly within the device; the second part is not included in this request. The Signia Stapling System and Ligasure XP Jaw Sealer/Divider are devices used by medical professionals during surgical procedures. They are marketed and sold exclusively to healthcare providers and are specifically designed for minimally invasive surgeries. These devices are intended solely for surgical applications: the Signia Stapling System for cutting and stapling tissue, and the Ligasure XP Jaw Sealer/Divider for dissecting, sealing, and dividing vessels. Your submission proposed classifying parts of medical devices under subheading 9018.90.8000 of the Harmonized Tariff Schedule of the United States (HTSUS), which covers other instruments and appliances

used in medical, surgical, dental or veterinary sciences and parts and accessories thereof. While we agree that these parts belong in heading 9018, we disagree with the subheading you suggested. The Signia Stapling System is battery powered, therefore it uses electricity to power its function and considered as “electro-medical” under subheading 9018.90.75, HTSUS, not under the “Other” category of subheading 9018.90.80, HTSUS. Additionally, the Ligasure XP Jaw Sealer/Divider uses high-frequency radio frequency electric currents for its function, which, as explained in HQ H152456, qualifies it as “electro-surgical apparatus.” Thus, it should be classified under subheading 9018.90.60, HTSUS. The applicable subheading for Part No. 3013-4 and Part No. 3013-6, both of which are parts of the Signia Stapling System will be 9018.90.7580, 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 and parts and accessories thereof: Other: Electro-medical instruments and appliances and parts and accessories thereof: Other: Other: Other.” The rate of duty is Free. The applicable subheading for Part 4210-2, a hollow, bobbin-shaped aluminum component part of Ligasure XP Jaw Sealer/Divider, will be 9018.90.6000, 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: Electro-medical instruments and appliances, other than parts and accessories thereof: Electro-surgical instruments and appliances, other than extracorporeal shock wave lithotripters; all the foregoing and parts and accessories thereof.” The rate of duty is 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 P. Forkan Director National Commodity Specialist Division