The tariff classification of stainless steel transfer needles from China

N324873 March 31, 2022 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8688; 9903.88.03 Mr. Adrian Samkian Silver Point Labs LLC 155 N. Lake Ave. Pasadena, CA 91101 RE: The tariff classification of stainless steel transfer needles from China Dear Mr. Samkian: In your letter dated March 17, 2022, you requested a tariff classification ruling. Product information and photographs were submitted for our review. The product under consideration is identified as a stainless steel disposable liquid transfer needle and described as “a special type of needle for transferring reagents and/or chemicals from one container to another in a research laboratory setting. These needles are not designed for medical, human, or drug use despite their resemblance to common hypodermic needles.” They are designed to be a disposable alternative to the currently available non-sterile, reusable stainless steel transfer needles. The subject needles will consist of a standard polypropylene Luer lock base bonded to a hollow stainless steel needle with a bevel tip. You stated that “They are intended to be paired with any fitting syringe, however, the syringes will not be provided by us.” The needles will range in size from 18 to 24 gauge in thickness and from 4 to 12 inches in length, not including the hub. The extended length transfer needles will be used for transferring hazardous, pyrophoric, or sensitive chemicals and solvents to and from containers. The transfer needles will be exported from China in boxes, each containing 10 bags of 200 needles. The needles will be shipped with their points individually protected with polyethylene safety sleeves to mitigate potential hazards from the sharp points. The applicable subheading for the stainless steel transfer needles will be 7326.90.8688, Harmonized Tariff Schedule of the United States, HTSUS, which provides for other articles of iron or steel: other…other. The rate of duty will be 2.9 percent ad valorem. 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 at https://hts.usitc.gov/current. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7326.90.8688, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7326.90.8688, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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 ann.taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division