The status under the United States-Singapore Free Trade Agreement (SFTA) of NextVein Projection Vein Finder from Singapore

N353783 October 10, 2025 CLA-2-90:OT:RR:NC:N3:135 CATEGORY: Free Trade Agreement Ron Goldman NextVein LLC 2 Union Place Huntington, NY 11743 RE: The status under the United States-Singapore Free Trade Agreement (SFTA) of NextVein Projection Vein Finder from Singapore Dear Mr. Goldman: In your letter dated September 16, 2025, you requested a ruling on the status of the NextVein Projection Vein Finder from Singapore under the United States-Singapore Free Trade Agreement (SFTA). The NextVein Projection Vein Finder is a hand-held, vein scanning and projection device that assists trained medical personnel to locate a suitable position for venipuncture and other medical procedures requiring the location of superficial veins. The device operates by emitting infrared light to illuminate the patient's skin, thereby enhancing the contrast of veins against surrounding tissues. An integrated infrared-sensitive camera captures these illuminated images. Digital algorithms then process these images to highlight the vein patterns, which are subsequently projected directly onto the patient’s skin via a built-in micro projector. You claim the raw materials, including plastic parts, printed circuit boards, and product labels, are sourced from China. The assembly process is carried out in Singapore. During and after assembly, the product undergoes a series of functional and performance tests. The device is then inspected, packaged, labeled, and exported from Singapore to the United States. General Note 25(b), Harmonized Tariff Schedule of the United States (HTSUS), sets forth the criteria for determining whether a good is originating under the SFTA. General Note 25(b), HTSUS, (19 U.S.C. § 1202) states, in pertinent part, that For the purposes of this note, subject to the provisions of subdivisions (c), (d), (n) and (o) thereof, goods imported into the customs territory of the United States are eligible for treatment as originating goods of a SFTA country under the terms of this note only if they- (i) were wholly obtained or produced entirely in the territory of Singapore or of the United States, or both; (ii) are goods that, in their condition as imported, are enumerated in subdivision (m) of this note and imported from the territory of Singapore; or (iii) have been transformed in the territory of Singapore or of the United States, or both, so that each non-originating material: (A) undergoes an applicable change in tariff classification set out in subdivision (o) of this note as a result of production occurring entirely in the territory of Singapore or of the United States, or both; or (B) if no change in tariff classification is required, the good otherwise satisfies the applicable requirements set forth in such subdivision (o). General Note 25 (m), HTSUS, states, in relevant part, that Goods that shall be considered originating goods. For the purposes of subdivision (b)(ii) of this note, goods that, in their condition as imported, are classifiable in the tariff provisions enumerated in the first column and are described opposite such provisions, when such goods are imported into the customs territory of the United States from the territory of Singapore, shall be considered originating goods for the purposes of this note: Heading/Subheading Articles Subject to this Note (142) 9018 Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight testing instruments; parts and accessories thereof In this case, the NextVein Projection Vein Finder is classifiable under 9018, HTSUS, which provides for “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof.” Based on the facts provided, the NextVein Projection Vein Finder described above qualifies as an originating good for preferential treatment under the SFTA regardless of whether it meets the tariff shift rule under GN 25 (o). This is because it will meet the requirements of HTSUS General Note 25(b)(ii) provided all other applicable laws, regulations, and agreements are met. Goods imported from Singapore and treated as originating goods under general note 25(m) of the HTSUS for purposes of the SFTA will not use the SPI “SG.” Instead, these goods will be entered under the primary tariff number 9999.00.84, and the secondary tariff number (the appropriate 10-digit statistical reporting number from chapters 1 through 97) will appear on the next line. Even these goods with Singapore as the country of origin should be entered using the Chapter 99 number. You state the country of origin of the NextVein Projection Vein Finder is Singapore, but do not seek a ruling for a country of origin determination. Please note that CBP relies on the substantial transformation analysis when determining the country of origin for purposes of duties and marking. If you desire a ruling on the country of origin, you may submit a new ruling request with additional information including (1) the name, detailed description, clear color images, use/function, cost, and classification of each foreign component imported into Singapore. (2) Provide detailed step-by-step production details of the manufacturing process performed in Singapore. This information should contain a written explanation of the process, photos of the components being assembled, a description of the work being performed, equipment necessary for the assembly process, time, skill level required, attention to detail, quality control, testing, etc. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Fei Chen at fei.chen@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division