N350532

N350532 July 16, 2025 CLA-2-90:OT:RR:NC:N3:135 CATEGORY: Classification TARIFF NO.: 9021.10.0090; 9817.00.96 Christine Lam Mateside Global US Inc. 231 S Pleasant Ave. Ontario, CA 91761 RE: The tariff classification of rollators from China Dear Ms. Lam: In your letter dated June 24, 2025, you requested a tariff classification ruling. Photographs and product information were submitted for our review. Item # VOCIC Z21, Ergonomic Foldable 4-wheel Rollator Walker, is a foldable outdoor rollator consisting of a carbon iron frame, a seat, a 105 degree wrap around backrest, a dual brake system, 8-inch TPR wheels, adjustable armrests, plastic connectors, and reflective storage bags. The maximum load capacity is 330 lb. Item # Z11, Lightweight Foldable Rollator Walker, is a foldable rollator consisting of a carbon iron frame, a bionic double arc backrest (PE backrest), a seat, five-level adjustable armrests, a dual brake system (slow brake + parking brake), TPR wheels, plastic connectors, and a reflective storage bag. The maximum load capacity is 380 lb. Item # Z22, Upright Foldable Rollator Walker, is a foldable rollator with a patented gel shock-absorbing flip armrest covered with anti-slip particles. It consist of a carbon aluminum frame, five-level adjustable armrests, a fabric backrest, a seat, a dual brake system, a fabric bag, 8-inch TPR wheels, and plastic connectors. The maximum load capacity is 300 lb. Item # VOCIC Z51, Shift Combo 2 in 1 Rollator, is a foldable, 24 inch wide Transport Chair Walker that combines the features of an outdoor rollator and a wheelchair. It consist of an aluminum frame, a raised adjustable backrest which shifts the center of gravity backward to improve sitting safely, a seat, a dual brake system, 10-inch front wheels and 8-inch rear wheels, height-adjustable handles, a fabric bag, and plastic connectors. The maximum load capacity is 300 lb. Item # Z55, 2 in 1 Walker Wheelchair Combo, combines the features of a rollator and a wheelchair. It consist of an aluminum alloy oval tube frame, a two-way flip backrest that supports sitting and resting, a seat, 10-inch front wheels and 8-inch rear wheels, seven-level adjustable armrests, a dual brake system, plastic connectors, rotatable footrests, and a reflective storage bag. The maximum load capacity is 300 lb. The applicable subheading for all styles will be 9021.10.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]rthopedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability; parts and accessories thereof: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther. The general rate of duty will be free. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 9021.10.0090, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 9021.10.0090, HTSUS, listed above. However, the additional duties imposed by subheadings 9903.01.24 and 9903.01.25 shall not apply to goods for which entry is properly claimed under a provision of chapter 98 of the tariff schedule pursuant to applicable regulations of U.S. Customs and Border Protection (“CBP”), and whenever CBP agrees that entry under such a provision is appropriate, except for goods entered under heading 9802.00.80; and subheadings 9802.00.40, 9802.00.50, and 9802.00.60. You state that these products have been designed for dependent individuals who need assistance walking and do not want to lose their independence. In your submission, you requested consideration of a secondary classification under subheading 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. Customs and Border Protection has previously ruled that similar rollators and walkers are eligible for subheading 9817.00.96, HTSUS. See Headquarter ruling 561117 (November 16, 1998), NY rulings N235453 (December 12, 2012), and N325579 (May 5, 2022). Accordingly, a secondary classification will apply for these items in HTS 9817.00.96, HTSUS. The tariffs and additional 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/. 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) James Forkan Acting Director National Commodity Specialist Division

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) James Forkan Acting Director National Commodity Specialist Division