RE: The tariff classification of Castroviejo calipers from Germany

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363873 August 21, 2026 CLA-2-90:OT:RR:NC:N3:143 CATEGORY: Classification TARIFF NO.: 9018.90.8000 Adam Gustafson STERIS 5960 Heisley Rd Mentor, OH 44060 RE: The tariff classification of Castroviejo calipers from Germany Dear Mr. Gustafson: In your letter dated July 30, 2026, you requested a tariff classification ruling. Additional information was provided by email on August 11, 2026. The item under consideration is the Castroviejo caliper, part number MO9930, a compact, precision-engineered, reusable surgical instrument used to measure small distances between anatomical structures during surgical procedures. It is particularly used in ophthalmic surgery and is also common in dental and orthopedic procedures. Manufactured from high-grade, corrosion-resistant surgical stainless steel, the caliper is designed to withstand repeated sterilization cycles in clinical environments. It features a handheld, straight-tip configuration with needle-like measuring points rather than broader jaws, allowing for precise incremental adjustments. The caliper has a manual-read measurement range of 0 mm to 40 mm, marked in precise millimeter increments, and includes an adjustable thumbscrew mechanical locking mechanism that secures the measuring tips in place to ensure stable, accurate, and repeatable measurements during intricate procedures. As you state, the Castroviejo caliper is designed, marketed, and typically selected for use in microsurgical procedures, and its limited measuring range, delicate pointed tips, higher cost, and lower versatility make it less suitable than conventional precision calipers for general workshop or craft applications. In your letter, you suggest the Castroviejo Calipers (part number MO9930) to be classified in subheading 9017.30.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Drawing, marking-out or mathematical calculating instruments (for example, drafting machines, pantographs, protractors, drawing sets, slide rules, disc calculators); instruments for measuring length, for use in the hand (for example, measuring rods and tapes, micrometers, calipers), not specified or included elsewhere in this chapter; parts and accessories thereof: Micrometers, calipers and gauges: Micrometers and calipers.” We disagree. The Castroviejo Calipers are not general-use calipers and instead are specialized medical-grade surgical instruments designed exclusively for measuring tiny anatomical structures during delicate
ophthalmic, micro, or orthopedic procedures. Additionally, heading 9017 covers hand-held length-measuring instruments (like micrometers and calipers) only if they are “not specified or included elsewhere in this chapter.” Since medical and surgical instruments are specifically included elsewhere, under heading 9018, any measuring tool that is specially designed for surgical use is legally blocked from entering heading 9017. Accordingly, heading 9017 is excluded from consideration. The applicable subheading for the Castroviejo calipers (part number MO9930) will be 9018.90.8000, HTSUS, which provides for “Instruments and appliances used in medical, surgical, dental or veterinary sciences …parts and accessories thereof: Other instruments and appliances 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 P. Forkan Director National Commodity Specialist Division