The tariff classification of a heart rate monitor from Malaysia.

N362258
July 1, 2026
CLA-2-90:OT:RR:NC:N1:105
CATEGORY: Classification
TARIFF NO.: 9029.20.4080
Woongchan Yum Roberts & Kehagiaras LLP 2339 Commerce Street, Suite 162 Houston, TX 77002 RE: The tariff classification of a heart rate monitor from Malaysia. Dear Mr. Yum: In your letter dated June 11, 2026, on behalf of your client, Interactive Health Technologies, LLC., you requested a tariff classification ruling. Descriptive literature was provided for our review. The merchandise under consideration is the IHT Spirit Heart Rate Monitor (Spirit HRM), a wrist-worn, battery-powered, Bluetooth-enabled wireless wearable health device engineered to monitor and track physical effort. This device features a secure, multi-component plastic housing comprising a top cover, a bottom cover, a sealing rubber gasket, and an adjustable wrist strap, all designed within an IP-rated waterproof enclosure for active use. Internally, its operation is managed by a Main Board containing a Microcontroller Unit (MCU), control circuitry, a rechargeable internal battery, and a digital display screen. Magnetic charger connectors are integrated into the lower casing for recharging. The system incorporates an optical heart rate sensing module (OHR Board) that utilizes photoplethysmography (PPG) technology. It emits light through a dedicated OHR lens via LED emitters into the user’s skin, while photodiode sensors capture backscattered light signals to measure volumetric blood changes. The device calculates and displays real-time physiological and operational metrics, including heart rate (beats per minute), heart rate zone status, minimum/maximum heart rate, elapsed time in active zones, activity goal progress, date/time, and battery depletion status. Wireless data transmission is facilitated by an integrated Bluetooth module. System activation, long-term historical data logging, reporting, and group metric management require pairing with a compatible host smart device running the proprietary Spirit Software Suite, which includes classroom, assessment, and individual platforms. The unit does not support cellular or standard smartphone notifications such as calls, emails, or text alerts. In your letter you suggest classification within heading 8517, Harmonized Tariff Schedule of the United States (HTSUS). As described above, the device utilizes an incorporated optical heart rate sensing module and imbedded software to calculate and display real-time physiological and operational metrics including

heart rate (beats per minute), heart rate zone status, minimum/maximum heart rate, elapsed time in active zones, activity goal progress, date/time, and battery depletion status. Additionally, this device uses Bluetooth technology to wirelessly transmit that data to a tethered device for additional tracking functionality. Heading 8517, HTSUS, provides in relevant part for: “…other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network).” The item concerned is primarily used to monitor various aspects of a person’s wellbeing. It incorporates sensors and a processing system that measures/calculates health related statistics. It also has a secondary function of transmitting that data to a remote Bluetooth enabled device. Classification under heading 8517, HTSUS, is precluded because the device concerned is a composite good (Section XVI Note 3 and Chapter 90 Note 3) which execute the principal function of determining or calculating a measurement. The ability to transmit that information to a remote device would be considered the unit’s secondary or support function. As per the Explanatory Notes to heading 8517, carrier-current and other transmitters and receivers which form a single unit with analogue or digital telemetering instruments or apparatus…, are excluded from heading 8517. Additionally, measurement apparatus of Chapter 90 is excluded from classification within Chapter 85. As such classification within heading 8517. HTSUS is not applicable. The applicable subheading for the heart rate monitor will be 9029.20.4080, HTSUS, which provides for “Revolution counters, production counters, taximeters, odometers, pedometers and the like; speedometers and tachometers, other than those of heading 9014 or 9015; stroboscopes; parts and accessories thereof: Speedometers and tachometers; stroboscopes: Other speedometers and tachometers: 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 Jason Christie at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division