The tariff classification of an electronic portable drug delivery system

NY D81415 September 1, 1998 CLA-2-90:RR:NC:MM:105 D81415 CATEGORY: Classification TARIFF NO.: 9018.90.7580 Mr. Jacques de Neuville Physior USA 161 West 54th Street, Suite 202 New York, NY 10019 RE: The tariff classification of an electronic portable drug delivery system Dear Mr. de Neuville: In your letters, dated June 30 and August 10, 1998, you requested a tariff classification ruling. The IZZO system is used during clinical trials for solid form drugs by pharmaceutical drug manufacturers. Pills are put into its compartments and are normally removed by the patient for his use. This system detects the removal of the pill from a compartment and stores that information and the time of occurrence on an electronic recorder. The information is eventually downloaded by a health care professional employed on behalf of the organization running the drug trial for incorporation into the data base which maintains the information concerning the drug usage. The purpose is to have some automatic, non-subjective evidence that the pills were taken in accordance with the protocols of the trial concerning the time and quantity of dosage. The applicable subheading for this item will be 9018.90.7580, Harmonized Tariff Schedule of the United States (HTS), which provides for certain electro-medical apparatus, other than electro-diagnostic. The general rate of duty will be 0.8 percent ad valorem. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist James Sheridan at 212-466-5669. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division