The tariff classification of a Nasal Atomizer Assembly from China.

N363546August 13, 2026CLA-2-90:OT:RR:NC:N3:143
CATEGORY: Classification
TARIFF NO.: 9019.20.0000
Jeffrey PhippsAlcove Medical, Inc.2318 N Wonser LNCedar City, UT 84721RE: The tariff classification of a Nasal Atomizer Assembly from China.Dear Mr. Phipps:In your letter dated
July 22, 2026
, you requested a tariff classification ruling. Additional information wasprovided by email on July 30, 2026, July 31, 2026, and August 3, 2026.The item under consideration is a nasal atomizer assembly designed to help deliver atomized medication intothe nasal passage. The assembly consists of two components: an atomizer tip and an atomizer body. Bothcomponents are made of medical-grade polycarbonate and are imported together but unassembled. Theatomizer tip is a cone-shaped, injection-molded component that attaches to the atomizer body, which is atube-shaped component with a central winged grip and a luer lock connector. After importation, the twocomponents are assembled to form the nasal atomizer assembly, which is then attached to a luer lock syringeor another mechanical delivery mechanism for use. Once the syringe and the nasal atomizer assembly areconnected, they form an intranasal mucosal atomization device. The syringe is not included in this request.In use, the atomizer body connects the tip to the syringe and provides a passageway for medication to flowfrom the syringe to the tip. The atomizer tip creates the atomized spray through internal swirl vanes thatbreak the fluid into fine droplets, while its conical shape seals the device against the patient’s nostril, helpingreduce medication backflow and preventing the device from being inserted into the nostril.You suggest classification under subheading 9018.31.0090, Harmonized Tariff Schedule of the United States(HTSUS), which provides for “Syringes, needles, catheters, cannulae and the like; parts and accessoriesthereof.” We disagree. The atomizer tip and body are components of the atomizer assembly, which areintended to spray liquid medication in aerosol form into the user’s nasal passage. Although it is designed toconnect to a syringe for medication administration, it is not a part or accessory of the syringe itself.Therefore, it will be classified elsewhere.
You also suggest classification under subheading 9018.90.8000, HTSUS, which provides for “Instrumentsand appliances used in medical, surgical, dental or veterinary sciences… parts and accessories thereof: otherinstruments and appliances and parts and accessories thereof: other: other.” Again, we disagree. Although thenasal atomizer assembly is used in medical, surgical, dental, or veterinary sciences, its more specific functionis to produce an atomized medicated spray by shearing liquid medication into fine droplets. As such, it willbe classified elsewhere.The applicable subheading for the nasal atomizer assembly will be 9019.20.0000, HTSUS, which providesfor “Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respirationapparatus; parts and accessories thereof.” 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 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 Dionisia Melman at [email protected].
Sincerely,
(for)James P. ForkanDirector
National Commodity Specialist Division