The tariff classification of NayaTouch Handles and Cartridges from China and Taiwan

November 24, 2009 N082724 CLA-2-73:OT:RR:E:NC:N1:113 TARIFF NO.: 7326.90.8588; 3926.90.9980 Mr. Erik Pampalone NayaTouch, Inc. 21800 Devonshire Street Chatsworth, CA 91311 RE: The tariff classification of NayaTouch Handles and Cartridges from China and Taiwan Dear Mr. Pampalone: In your letter dated November 2, 2009, you requested a tariff classification ruling on NayaTouch Handles and Cartridges. Advertising and marketing literature, instruction manuals, copies of photographs and flow charts for NayaTouch products were submitted for our review. You indicated in your letter that the handles and cartridges will be made in China. You also stated that the NayaTouch products will be imported from a manufacturer in Taiwan. The subject articles are identified as the NayaTouch Handles, and the 300 micron and 600 micron models of NayaTouch Cartridges. The NayaTouch products are designed to penetrate the top layers of the skin. They work by assisting the skin in the absorption of cosmetic creams, lotions, oils, serums, and topical anesthetics to reduce and remove pain associated with hair removal. The handle is made of stainless steel and packed in a plastic clamshell package. It is designed for repeated use by a professional medical operator, technical service person or a consumer. The NayaTouch Cartridges are made of plastic and each cartridge is packaged and sealed in a sterile package. A set of cartridges are packaged inside a clamshell and packed inside a box. You stated that the handles and the cartridges will be imported separately, and the cartridges will be imported in packs. You also indicated that the first shipments may contain handles packaged in clamshells and cartridge packs in clamshells. The applicable subheading for the NayaTouch Handles will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem. The applicable subheading for the NayaTouch Cartridges will be 3926.90.9980, HTSUS, which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem. Duty rates are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Ann Taub at 646-733-3018. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division