The tariff classification of a wireless patient feedback device from Mexico

N265734 June 26, 2015 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Ms. Karia Herrera Compliance Manager R.L. Jones Customhouse Brokers 8830 Siempre Viva Road, Suite 100 San Diego, CA 92154 RE: The tariff classification of a wireless patient feedback device from Mexico Dear Ms. Herrera: In your letter dated June 12, 2015, you requested a tariff classification ruling. The item concerned is referred to as a patient feedback tool, model # 4520. This is a small handheld electronic device used in the medical field to wirelessly (Bluetooth) transmit feedback information from a patient to a controller/programmer unit. This feedback device is used in conjunction with a spinal cord stimulation system. Part of the spinal cord stimulation system is a pulse generator (which may or may not be implanted in the patient, depending on the type used). The pulse generator is used to provide electrical stimulation to a specific area of the spinal cord. The system is used as therapy to manage chronic intractable pain of the trunk and/or limbs. The clinician programmer device is used to customize a program, based on the needs of the individual patient, which will be downloaded to the pulse generator. During the programing procedure the clinician programmer device would be connected to the pulse generator(s). As the doctor made changes or adjustments to the program the patient would actually feel the stimulus or electric shock and use the wireless handheld feedback tool to communicate that fact to the clinician programmer device. As the doctor went through all the required programming steps the patient would continually use the feedback tool to provide input. The feedback tool is simply a wireless (Bluetooth) transceiver that is used to transmit very basic feedback data to another device. In the absence of the feedback tool, the patient could provide the feedback by taping the screen of the clinician programmer. The feedback tool just makes the process easier and more efficient. The applicable subheading for the patient feedback tool, model # 4520, will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “…: Other apparatus for transmission or reception of voice, images or other data…: Machine for the reception, conversion and transmission or regeneration of voice, images or other data…: Other.” The rate of duty will be Free. 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 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 Steven Pollichino at Steven.Pollichino@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division