The tariff classification of ramp segments for accessibility ramps from China

N360786May 11, 2026CLA-2-76:OT:RR:NC:N1:113
CATEGORY: Classification
TARIFF NO.: 7616.99.5190; 9817.00.96
Samantha HethDT & J Inc dba Roll-A-Ramp1816 4th Ave NW, Unit CWest Fargo, ND 58078RE: The tariff classification of ramp segments for accessibility ramps from ChinaDear Ms. Heth:In your letter dated
April 16, 2026
, you requested a tariff classification ruling. Informational material wassubmitted with your request.The items under consideration are ramp segments for Roll-A-Ramp’s B45237 series of accessibility ramps.These ramps provide a versatile, portable aluminum ramp system designed for wheelchairs, scooters, andwalkers. The ramp segments provide the primary structure and indispensable physical qualities the finishedramps rely on to function. Each segment measures 6 inches (in.) in length, with varying widths of 30 in., 36in., or 48 in. resembling a rectilinear stair tread. The treads for each segment feature evenly spaced ovalperforations and parallel non-slip serrations on its surface to provide traction. Each segment also has twoaluminum flange plates on each side extending below and above the tread. The area below the tread has twobolt holes where the hardware is installed to ultimately assemble the ramp, and the area above defines theedge of the tread and the ramp overall. These features are instrumental in ensuring individuals and theirequipment can safely transverse the finished ramp from end to end mitigating tripping and falling hazards. When assembled into a ramp, the overall length will be determined by the number of segments that arecombined together, and the width will depend on the customer’s order and means for accessibility. Eachramp features a unique roll-up design for easy transport and storage and are designed to accommodate a loadof 1,500 pounds. Heading 7616, Harmonized Tariff Schedule of the United States (HTSUS), is a residual or basket provisionwhich covers a wide range of aluminum articles that are not more specifically provided for elsewhere in theHTSUS. The Explanatory Notes (ENs) to heading 7616 state that “This heading covers all articles ofaluminum other than those covered by the preceding headings of this Chapter, or by Note 1 to Section XV, orarticles specified or included in Chapter 82 or 83, or more specifically covered elsewhere in the
Nomenclature.” An article of aluminum can be classified in heading 7616, HTSUS, if it is determined thatthe item is not more specifically provided for in any other heading of the tariff. The ramp segments are notspecifically covered elsewhere in the tariff. Accordingly, they are classifiable in heading 7616, HTSUS.The applicable subheading for the ramp segments will be 7616.99.5190, HTSUS, which provides for “Otherarticles of aluminum: Other: Other: Other: Other: Other.” The general rate of duty will be 2.5 percent advalorem.In your submission you requested consideration of a secondary classification for the subject accessibilityramps under 9817.00.96, HTSUS, which applies to articles and parts of articles specifically designed oradapted for the use or benefit of the permanently or chronically physically or mentally handicapped. Chapter98, Subchapter XVII, U.S. Note 4(a), HTSUS, defines the term blind or other physically or mentallyhandicapped persons as including “any person suffering from a permanent or chronic physical or mentalimpairment 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.”The primary issue is whether the article is specially designed or adapted for the use or benefit of thehandicapped within the meaning of Nairobi Protocol. The Nairobi Protocol to the Agreement on theImportation of Educational, Scientific, and Cultural Materials Act of 1982, established the duty-freetreatment for certain articles for the handicapped. Presidential Proclamation 5978 and Section 1121 of theOmnibus Trade and Competitiveness Act of 1988, provided for the implementation of the Nairobi Protocolinto subheadings 9817.00.92, 9817.00.94, and 9817.00.96, HTSUS. These tariff provisions specifically statethat “articles specially designed or adapted for the use or benefit of the blind or other physically or mentallyhandicapped persons: parts and accessories (except parts and accessories of braces and artificial limbprosthetics) that are specially designed or adapted for use in the foregoing article are eligible for duty-freetreatment.”In Headquarters Ruling Letter 556449, dated May 5, 1992, U.S. Customs and Border Protection (CBP) setforth five factors it would consider in determining whether an article is specially designed or adapted for theuse or benefit of handicapped persons. These factors include: (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 usespecific to this unique design, from articles useful to non-handicapped persons); (2) whether anycharacteristics are present that create a substantial probability of use by the chronically handicapped so thatthe article is easily distinguishable from articles useful to the general public and any use thereof by thegeneral public is so improbable that it would be fugitive; (3) whether articles are imported by manufacturersor 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 thecondition of the articles at the time of importation indicates that these articles are for the handicapped.Roll-A-Ramp is a vendor that specializes in selling and assembling accessibility ramps. The ramp segmentsfor series B45237 have physical properties and characteristics that facilitate accessibility and are importedwith those features. The ruling request also cites a previous ruling issued to Roll-A-Ramp, New York rulingK82007, dated January 14, 2004, which concerned a complete Roll-A-Ramp system that was found to beeligible for a secondary classification under 9817.00.96, HTSUS. Therefore, the ramp segments forRoll-A-Ramp’s B45237 series qualify 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 providedat https://hts.usitc.gov/.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Matthew Gay at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division