The tariff classification of medical device trainers from China

N285821 May 25, 2017 CLA-2-90:OT:RR:NC:N1:405 CATEGORY: Classification TARIFF NO.: 9023.00.0000 Syed Bukhari Noble International, Inc. 121 South Orange Avenue Orlando, FL 32801 RE: The tariff classification of medical device trainers from China Dear Mr. Bukhari: In your letter dated April 27, 2017, you requested a tariff classification ruling. The products at issue are described as device trainers, articles designed to resemble and mimic the function of self-administered commercial drug delivery platforms. The products covered by your submission are identified as the Autoinjector Device Trainer, the Prefilled Syringe Device Trainer, and the Respiratory Device Trainer. The Autoinjector Device Trainer is designed to simulate the attributes of autoinjectors. The training device mimics the shape, design, and tactile feel of a real autoinjector. Additionally, the device features internal components that replicate the actuation forces, plunger drop speed, and the sound of an activated autoinjector. The devices can be reset and are intended to familiarize a patient with the operation of an autoinjector and enable them to repeatedly practice using it until they are adept enough to self-administer medication with an actual autoinjector. The Prefilled Syringe Device Trainer simulates the features and functions of prefilled syringe drug delivery devices. The training device replicates the shape, design, and feel of a real prefilled syringe device. The device features a ball tip simulation needle, a simulation needle cap, and a working plunger. The device trainer is intended to familiarize a patient with the operation of a prefilled syringe, and enable them to safely learn the force and technique required to insert a real prefilled syringe into their skin. The Respiratory Device Trainer is designed to simulate the characteristics of a real pulmonary drug delivery device, specifically a metered dose inhaler. The training device replicates the shape, design, and operational sequence of a real inhaler. The device is intended to familiarize a patient with the operation of the inhaler, enabling them to repeatedly practice the proper priming, cleaning, actuating, and inhaling procedures. All of the abovementioned device trainers are designed to safely demonstrate to patients the proper methods of self-administering medication by replicating the operation of the real drug delivery platforms. None of the devices contain any medicaments, but they replicate the operation of the real devices that they represent. The device trainers are not suitable for any use other than enabling a user to familiarize themselves with the operation of a drug delivery device by way of repeated practice. In this respect, the medical device trainers are similar in form and function to the Smartject Re-Usable Trainer described in New York Ruling Letter N072795, dated August 26, 2009. The applicable subheading for the medical device trainers will be 9023.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Instruments, apparatus and models, designed for demonstrational purposes (for example, in education or exhibitions), unsuitable for other uses, and parts and accessories thereof. 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 https://hts.usitc.gov/current. 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 Evan Conceicao at evan.m.conceicao@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division