The tariff classification of a disposable CLIC absorber from Germany

N359872 April 1, 2026 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 8421.39.0190 Samantha Summey Draeger Medical Systems, Inc. 3135 Quarry Rd Telford, PA 18969 RE: The tariff classification of a disposable CLIC absorber from Germany Dear Ms. Summey: In your letter dated March 19, 2026, you requested a tariff classification ruling. Descriptive literature was provided for our review. The items under consideration are described as disposable CLIC absorbers, which are devices designed for use with Dräger anesthesia workstations and compatible respiratory therapy equipment. The absorbers are sealed plastic cartridges containing a carbon dioxide absorbent material (typically soda lime or equivalent chemical compound). During anesthesia or respiratory therapy, the patient’s exhaled gases pass through the absorber. The absorbent material chemically removes carbon dioxide from the gas mixture, allowing the remaining gases to be recirculated safely to the patient. The CLIC absorber is designed to fit Dräger anesthesia systems using the proprietary CLIC mounting interface. Each model number (MX0004, MX50004, MX50100, MX50120, MX00001, and MX50050) operates in a similar way but contains a slightly different shape that works with different machines. You proposed classification under subheading 9019.20.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof.” The intended function of the subject CLIC absorbers are to remove carbon dioxide from exhaled gases. Chapter 90 Note 2 (a) states “that parts and accessories which are goods included in any of the headings of this chapter or of chapter 84, 85 or 91 (other than heading 8487, 8548 or 9033), are in all cases to be classified in their respective headings.” Since the CLIC absorber is a filtering device of heading 8421, it is excluded from classification in chapter 90. Accordingly, the applicable subheading for the disposable CLIC absorber will be 8421.39.0190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Other: Other: Other: Other.” The general rate of duty will be free. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division