RE: The tariff classification of battery-powered dental examination lightning products from Israel

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365361 October 13, 2026 CLA-2-90:OT:RR:NC:N3:143 CATEGORY: Classification TARIFF NO.: 9018.49.8080 Kristine Thompson Andau Medical Corp. 923 Industry Drive Tukwila, WA 98188 RE: The tariff classification of battery-powered dental examination lightning products from Israel Dear Ms. Thompson: In your letter dated September 24, 2026, you requested a tariff classification ruling. Additional information was also provided by email. There are three products under consideration: the Orchid series, Butterfly EVO series, and Flamingo HD Camera and Light System. All three are battery-powered LED headlight systems; however, the Flamingo system also includes an HD camera. As you indicated, the products are designed for use by dental and medical professionals and attach to compatible loupes or eyewear to illuminate dental or surgical procedure area. The Orchid series includes the Orchid, Orchid-F, Orchid-E, and Orchid-S models. None of the models includes loupes, a camera, a microphone, or a headband. The models are powered by rechargeable PowerPack battery units and are imported with a battery charger, two PowerPack battery units, a light source, a yellow filter, a screwdriver, and an Allen key. The Allen key is included only with models having an external, removable yellow filter; depending on the model, the yellow filter is either external and removable or built into the light source. The light source is a high-power, LED-based headlight system used to illuminate dental or surgical procedure areas. It measures either 44 or 54 mm in length and 19 or 29 mm in width, weighs between 9 or 11 g, and has an aluminum body with certain internal plastic components. At a working distance of 350 mm, the light provides a spot size of either 60 mm or 80 mm and illumination ranging from 80 to 220 klux at a color temperature of 5,750 K. All models appear to serve the same function differing primarily in light intensity and the type of yellow filter included. The Butterfly EVO series consists of the Butterfly EVO and Butterfly-S EVO models. Neither model includes loupes, a camera, a microphone, or a headband. Each model is imported with a light source, three batteries, a charging pad, an external yellow filter, an AC/DC USB charger with a USB Type-C cable, a screwdriver, and an Allen key. The light source is a high-power, LED-based headlight system designed for use with loupes to illuminate dental and surgical procedure areas. It measures approximately 50 mm in width and 19 mm in diameter and weighs 9 g without the cable. Its exterior is made of aluminum, with certain internal plastic components. At a working distance of 350 mm, both models provide a 70 mm spot diameter. The Butterfly EVO provides illumination of 35 klux, while the Butterfly-S EVO provides 55 klux; both have a color temperature of 5,750 K. Both models appear to perform the same function and differ primarily in light intensity. The Flamingo is a battery-powered HD camera and light system designed to attach to compatible loupes or eyewear, which are not included. It incorporates an HD camera and light module that captures video and illuminates dental or surgical procedure areas, transmitting live video via Wi-Fi to Flamingo software on a computer. The light source is a high-power, LED-based headlight system with a 17 mm light diameter. The camera and light module weigh 19 g without the cable and have aluminum external components with certain internal plastic parts. At a working distance of 350 mm, the light provides a 90 mm spot diameter and illuminance of 70 klux at a color temperature of 5,750 K. Video recording is controlled through Flamingo software and a wireless foot pedal, with recordings stored locally on the computer. The imported kit includes the camera and light module; a camera-module cable; a Main Control Unit/PowerPack with two rechargeable batteries; a charging stand and AC/DC adapter; a wireless foot pedal and Type-C charging cable; power and connection cables; a Wi-Fi USB dongle and USB-A adapter; tools and accessories for assembly, adjustment, cable routing, and mounting to compatible loupe frames; an external yellow composite filter; and a working-distance/focus card. The Explanatory Notes to the Harmonized Tariff System, although not legally binding, provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3(b) provides that the term "goods put up in sets for retail sale" means goods that; (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without re-packing. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. GRI 3(c) provides that when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in numerical order among those which equally merit consideration. In our opinion, the Orchid series, Butterfly EVO series and Flamingo HD Camera and Light System components are all classified in different headings. However, they are used together to accomplish a specific activity and are packaged together for retail sales. Therefore, the Orchid, Butterfly EVO and Flamingo HD Camera and Light System series are “goods put up in sets for retail sale.” The Orchid series, Butterfly EVO series, and Flamingo HD Camera and Light System have some of the same characteristics as surgical lights, as described in Trumpf Medical Systems, Inc. v. United States, 753 F. Supp. 2d 1297 (2010). Additionally, our review of the brochures and manuals provided for all series indicates that these products are marketed primarily for use in dental settings. Pursuant to GRI 3(b), we are of the opinion that the light source imparts the essential character of the Orchid and the Butterfly EVO series. With respect to the Flamingo HD Camera and Light System, we find that the system has two distinct functions: the HD camera function, which is described in heading 8525, and the light-source function, which is described in heading 9018 as an instrument or appliance used in medical or surgical sciences. Neither function imparts the essential character of the system; therefore, classification under GRI 3(b) is not possible. Pursuant to GRI 3(c), when goods cannot be classified by reference to GRI 3(a) or 3(b), they are classified under the heading that occurs last in numerical order among those that equally merit consideration. Because heading 9018 occurs after heading 8525, the Flamingo HD Camera and Light System is classified under heading 9018. The applicable subheading for the Orchid series, Butterfly EVO series, and Flamingo HD Camera and Light System. will be 9018.49.8080, Harmonized Tariff Scheduled of the United States (HTSUS), which provides for "other" instruments and apparatus used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof. 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 Dionisia Melman at dionisia.y.melman@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division