The tariff classification of components of Eclipse Oxygen Concentrator from China

N359765 April 9, 2026 CLA-2-90:OT:RR:NC:N3:143 CATEGORY: Classification TARIFF NO.: 9019.20.0000; 9817.00.96 David Robeson Mohawk Global Trade Advisors 123 Air Cargo Road North Syracuse, NY 13212 RE: The tariff classification of components of Eclipse Oxygen Concentrator from China Dear Mr. Robeson: In your letter dated March 16, 2026, you requested a tariff classification ruling behalf of your client, CAIRE Inc. The items in consideration are the Omni 1 (part 6963-SEQ), the Gimbal 30A (part 8057-SEQ), and the Outlet Barb (part 21498724-FITTING). These items are specifically designed and custom-made components for the Eclipse Oxygen Concentrator by Caire. Inc. The Omni 1 (part 6963-SEQ) is a plastic handler designed for the Eclipse unit. It features an arched shape with a straight-line distance of approximately six inches from end to end. The handle includes two screw cutouts, allowing it to be securely fastened to the hard case plastic on the back of the Eclipse. Its specific dimensions – thickness, length, and material- are engineered to provide comfortable carrying and transport the Eclipse unit without an additional stroller carriage. The Gimbal 30A (part 8057-SEQ) is a cross-shaped isolator made of silicone rubber with a hardness of Shore A 40 +/-5. It connects the compressor to the Eclipse unit, providing a soft interface between the rigid compressor surfaces. This component reduces sound and minimizes vibration transfer to the overall Eclipse unit, effectively isolating and dampening both sound and vibration generated by the compressor. The Outlet Barb (part 21498724-FITTING) is a specialized fitting made of aluminum 6061-T6. It attaches to the Eclipse unit using a screw and serves as the connection point for the plastic oxygen tube to the cannula. The Outlet Barb Fitting provides the exit point for oxygen from the Eclipse unit into the flexible breathing hose. The applicable subheading for the Omni 1 (part 6963-SEQ), the Gimbal 30A (part 8057-SEQ), and the Outlet Barb (part 21498724-FITTING) will be 9019.20.0000, HTSUS, which provides for “Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof.” The general rate of duty will be free. In your submission you also requested consideration of a secondary classification under 9817.00.96, HTSUS, which applies to articles and parts and accessories of articles specifically designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped. Subheading 9817.00.96, HTSUS, covers: “[a]rticles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing articles: [o]ther.” The term “blind or other physically or mentally handicapped persons” includes “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS. Subheading 9817.00.60, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles, dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS. In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308 (Fed. Cir. 2018), the United States Court of International Trade (CIT) explained that “specially” means “to an extent greater than in other cases or towards others” and “designed” means something that is “done, performed, or made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then, whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314. The Court of Appeals for the Federal Circuit CAFC) clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially designed,” the merchandise “must be intended for the use or benefit of a specific class of persons to an extent greater than for the use or benefit of others” and adopted the five factors used by CBP: (1) the physical properties of the article itself (i.e., whether the article is easily distinguishable by properties of the design, form, and the corresponding use specific to this unique design, from articles useful to non-handicapped persons); (2) whether any characteristics are present that create a substantial probability of use by the chronically handicapped so that the article is easily distinguishable from articles useful to the general public and any use thereof by the general public is so improbable that it would be fugitive; (3) whether articles are imported by manufacturers or distributors recognized or proven to be involved in this class or kind of articles for the handicapped; (4) whether the articles are sold in specialty stores which serve handicapped individuals; and, (5)whether the condition of the articles at the time of importation indicates that these articles are for the handicapped. In NY ruling N348892, dated May 27, 2025, CBP ruled that the HomeStyle Aspen Stationary Oxygen Concentrator qualified for duty-free treatment under subheading 9817.00.96, HTSUS. Additionally, in NY ruling N339124, dated April 12, 2024 CBP determined that the Freestyle Comfort portable oxygen concentrator and the Eclipse Oxygen System are designed for users with chronic breathing impairments and prescribed by doctors to the users for oxygen therapy, and parts that are specifically designed as parts of the oxygen concentrators, eligible for duty-free treatment under subheading 9817.00.96, HTSUS. Accordingly, the Omni 1 (part 6963-SEQ), the Gimbal 30A (part 8057-SEQ), and the Outlet Barb (part 21498724-FITTING) which are specifically designed components of the Eclipse Oxygen Concentrator, qualify for duty-free treatment under subheading 9817.00.96, HTSUS. The duties cited above are current as of this ruling’s issuance. 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Dionisia Melman at dionisia.y.melman@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division