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NY N016833

October 5, 2007



TARIFF NO.: 9018.90.7580

Mr. Michael Skidmore
Customs Consultant
103 Greenleaf Street
Quincy, MA 02169

RE: The tariff classification of an interface control from Germany

Dear Mr. Skidmore:

In your letters dated June 30 and August 27, 2007, for Karl Storz Endoscopy America, you requested a tariff classification ruling. No sample was provided

Per page 6 of the unannotated, 36 page instruction manual which you supplied, the Intended Use of this SCB (Storz Control Bus) interface control 20090120 is to enable up to 6 units to be controlled via the Karl Storz-SCB system R-UI user interface.

Per Exhibit B to your August 27 letter, Karl Storz-SCB technology offers centralized control over medical equipment and peripheral systems via touch screen in the sterile area.

The import is an AC powered box with female connections for RS 232 electrical connectors and an SCB electrical connector.

Per your August 27 letter, the peripheral systems would often include the overhead lighting in the surgery and the medical equipment would often include insufflators and surgical pumps.

We take it that the 20090120 is principally used with the medical equipment, which, from the examples, appears to be classifiable in HTSUS heading 9018. See Note 2-b to Chapter 90.

Separately imported parts and accessories, if identifiable as being suitable for use principally with a number of machines, instruments or apparatus of HTSUS 9018, are classifiable in its heading if not excluded from HTSUS Chapter 90 by its Note 2-a or 1 or by HTSUS Add. US Rule of Interpretation 1-c (see HRLs 965968, 12-16-02, and 967233, 2-18-05.)

Although the 20090120 is called a control device, we do not consider it to be for electric control or the distribution of electricity per the heading for HTSUS 8537 since it is not opening or closing electrical circuits.

Therefore, it does not appear to be excluded from HTSUS Chapter 90 by its Note 2-a or 1 or by HTSUS Add. US Rule of Interp. 1-c.

Within HTSUS 9018, it appears to be used principally with the devices of 9018.90, and within that, those of 9018.90.75.

We agree that the applicable subheading for the 20090120 will be 9018.90.7580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "other" Electro-medical instruments and appliances and parts and accessories thereof. The rate of duty will be free.

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 on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist J. Sheridan at 646-733-3012.


Robert B. Swierupski

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