N353937

N353937 October 9, 2025 CLA-2-90:OT:RR:NC:N3:135 CATEGORY: Classification TARIFF NO.: 9018.19.9560; 9903.01.24; 9903.01.25; 9903.88.01 Brian Smith Johnson Medtech, LLC 801 Scholz Dr Vandalia, OH 45377 RE: The tariff classification of an incomplete SurePulse VSP Patch from China Dear Mr. Smith: In your letter dated September 18, 2025, you requested a tariff classification ruling. Additional information was provided by email dated October 8, 2025. The product under consideration is an incomplete SurePulse VSP Patch, part number 1632-PFD0161, which you have identified as a “Flexible Printed Circuit” or “flexible printed circuit assembly.” The complete SurePulse VSP Patch is a component of the SurePulse wireless monitoring system, which includes three components: the Patch itself, a VSP Module, and a multi-parameter display. This non-invasive, wireless, multi-parameter vital sign monitoring platform is designed to continuously monitor and record electrocardiogram (ECG) waveforms, heart rate, and skin temperature in newborn babies. It is intended for use by medically qualified personnel in healthcare settings as a monitoring tool during the critical first moments of a child's life. At the time of import, the incomplete SurePulse VSP Patch comprises a flexible printed circuit assembly connected to two ECG traces (pads), both attached to a plastic sheet. The flexible printed circuit assembly has a flat cable (lead wire). The flexible printed circuit assembly, manufactured using surface mount technology, consists of a flexible printed circuit board and integrated electronic components. These components include a memory integrated circuit (IC), a microcontroller (MCU), analog devices, infrared and red LEDs, a photodiode, a temperature sensor, capacitors, and resistors. After importation into the United States, the incomplete SurePulse VSP Patch undergoes a final assembly process where a plastic cradle is added to the flat cable, the flat cable is attached to a paper carrier, two hydrogels are affixed to the ECG electrodes, and the ECG electrodes are themselves affixed to the ECG traces, and a foil is attached to the flexible printed circuit assembly. In your letter, you suggest classification under subheading 9018.11.6000, Harmonized Tariff Schedule of the United States (HTSUS), which covers printed circuit assemblies for electrocardiographs. However, the SurePulse wireless monitoring system is more than just an electrocardiograph. The imported item is an incomplete part of the SurePulse wireless monitoring system and will therefore be classified elsewhere. The applicable subheading for the incomplete SurePulse VSP Patch will be 9018.19.9560, HTSUS, which provides for “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences ...; parts and accessories thereof: [e]lectro-diagnostic apparatus …: [o]ther: [o]ther: [o]ther: [p]arts and accessories.” 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 9018.19.9560, 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 of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 9018.19.9560, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9018.19.9560, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 9018.19.9560, HTSUS, listed above. 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) Denise Faingar Designated Official Performing the Duties of the Division 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division