N356032

N356032 December 8, 2025 CLA-2-90:OT:RR:NC:N3:135 CATEGORY: Classification TARIFF NO.: 9021.10.0090; 9817.00.96 Myrna Nickelsen Core Mobility Solutions, Inc. 6341 San Ignacio Ave San Jose, CA 95119 RE: The tariff classification of LifeGlider from China Dear Ms. Nickelsen: In your letter dated November 14, 2025, you requested a tariff classification ruling. The LifeGlider is a patented mobility assistance device designed for individuals who have difficulty walking or standing due to neurological, muscular, or balance impairments. Unlike standard rollators or walkers that require upper-body support, the LifeGlider transfers the user’s body weight through the hips and pelvis to the frame, enabling upright and hands-free mobility. The device consists of two parallel side tubular steel frames joined by a hinge arm structure, a braking system, height-adjustable components to accommodate different users, a walking seat that bears part of the user’s weight, four wheels (front swivel, rear locking), and a seatbelt-style securing system that fastens around the waist to keep the user safely positioned while walking or standing. This configuration allows the user to move freely while preventing falls and eliminating the need to hold the frame for balance. The LifeGlider is shipped fully assembled. The device provides controlled mobility and fall prevention for individuals with compromised balance, strength, or endurance. It is used in home, rehabilitation, and clinical environments by individuals with conditions such as multiple sclerosis, Parkinson’s disease, ataxia, cerebral palsy, or those in post-stroke recovery. You state that the LifeGlider is exclusively designed for individuals with physical impairments that affect their ability to walk or maintain balance. These impairments are typically long-term and may result from medical conditions such as cerebral palsy, multiple sclerosis, Parkinson’s disease, muscular dystrophy, stroke, traumatic brain injury, or spinal cord injury. The LifeGlider provides upright, hands-free mobility and fall prevention by supporting the user’s pelvis and hips rather than requiring arm strength for balance. It is not suitable or marketed for general public use. Based on internal sales data and customer feedback, the majority of LifeGlider users — approximately 95% — have permanent or chronic mobility impairments. A small percentage (less than 5%) use the LifeGlider temporarily during rehabilitation following injury or surgery. In all cases, users experience substantial mobility limitations. The LifeGlider is unsuitable for non-disabled users due to its pelvic support system and structural design, which restrict normal gait but stabilize users with impaired balance. The product’s weight and controlled movement features make it cumbersome and unnecessary for able-bodied individuals. It is distributed exclusively through medical suppliers, rehabilitation professionals, and our own website. It is not marketed in general consumer retail channels. The LifeGlider is used by individuals with substantial limitations in walking or standing, regardless of whether those impairments are permanent or temporary. Examples include individuals recovering from stroke or surgery, and those with degenerative neurological conditions such as multiple sclerosis or Parkinson’s disease. In all cases, the LifeGlider serves to compensate for a physical disability by providing stability, weight support, and fall prevention. The applicable subheading for the LifeGlider 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 10 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 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 9021.10.0090, HTSUS, listed above. However, the additional duties imposed by headings 9903.01.24 and 9903.01.25 shall not apply to goods for which entry is properly claimed under certain provisions of Chapter 98 of the Harmonized Tariff Schedule of the United States (HTSUS). In your submission you requested consideration of a classification under 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. Subheading 9817.00.96, HTSUS, covers: “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing articles . . . Other.” The term “blind or other physically or mentally handicapped persons” includes “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS. Subheading 9817.00.96, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles, dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS. In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308 (Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent greater than in other cases or towards others” and “designed” means something that is “done, performed, or made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then, whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314. The Court of Appeals for the Federal Circuit (CAFC) clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially designed,” the merchandise “must be intended for the use or benefit of a specific class of persons to an extent greater than for the use or benefit of others” and adopted the five factors used by U.S. Customs and Border Protection (CBP): (1) the physical properties of the article itself (i.e., whether the article is easily distinguishable by properties of the design, form, and the corresponding use specific to this unique design, from articles useful to non-handicapped persons); (2) whether any characteristics are present that create a substantial probability of use by

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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division