The tariff classification of medical hydrogel from the United Kingdom

NY H88139 February 14, 2002 CLA-2-30:RR:NC:2:238 H88139 CATEGORY: Classification TARIFF NO.: 3006.70.0000 Mr. Jay Breda Compass Forwarding Co., Inc. 440 McClellan Highway East Boston, MA 02128 RE: The tariff classification of medical hydrogel from the United Kingdom Dear Mr. Breda: In your letter dated February 6, 2002, on behalf of your client, Bio-Detek, Inc., you requested a tariff classification ruling. The subject product, which you refer to as “medical hydrogel,” consists of a gel composed of a water-swollen network of hydrophilic homopolymers or copolymers. You state in your letter that the medical hydrogel will be manufactured in rolls of (typically) 100 linear meters and slit to various widths. The product also comes with plastic, release liners on each side to facilitate handling. After importation, the product will be cut to various finished shapes by your client, for use in the manufacture of defibrillator, non-invasive pacing, cardioversion, and ecg-monitoring electrodes, where it functions as the actual conducting element. Lastly, you state that the gel formula has been developed for optimum use for the previously-stated application, and that “[t]hese (i.e., electrodes) are the only types of products that our client manufacturers (sic).” The applicable subheading for the subject product will be 3006.70.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Gel preparations designed to be used in human or veterinary medicine as a lubricant for parts of the body for surgical operations or physical examinations or as a coupling agent between the body and medical instruments. The rate of duty will be 5 percent ad valorem. This merchandise may be subject to the requirements of the Federal Food, Drug, and Cosmetic Act, which is administered by the U.S. Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number 301-443-1544. 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 Harvey Kuperstein at 646-733-3033. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division