N358350

N358350 February 27, 2026 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.18.0050, 8518.21.0000, 8518.40.2000 Jamal Ayache Serene Group, Inc. 3401 E University Dr., Suite 206 Denton, TX 76208 RE: The tariff classification of four assistive telecommunication devices from China Dear Mr. Ayache: In your letter dated January 29, 2026, you requested a tariff classification ruling. This request covers four (4) distinct models of assistive telecommunication devices designed to compensate for sensorineural hearing loss. The first item concerned is referred to as the HD-40P Amplified Telephone. This device is a corded telephone with a 26dB+ gain, tone control, and a cognitive photo-memory dialing for users with dementia. It is stated that this telephone is engineered strictly for individuals with moderate-to-severe sensorineural hearing loss and dementia. As such it has been modified to incorporate the following: Photo Memory keys for users with dementia. Large keypads for visually impaired. Tone control to boost low or high frequency speech consonants. Speech amplification button and Volume control to increase volume by 26dB+ The second item concerned is referred to as the UA-30 Handset Amplifier. This device is an add-on amplifier (30dB+) that connects to a standard telephone handset. It is used to boost the received audio volume for a hard of hearing user. It is stated that this is a specialized amplifier designed to strap on to a telephone handset. It utilizes an internal microphone to pick up the handset audio and then amplifies that audio and directs it out through its internal speaker. It incorporates the following: Strap to attach to existing phone handset. Volume control. Pinhole for microphone to pickup phone handset audio. High-Gain amplifier PCB 30dB+. Speaker. The third item concerned is referred to as the UA-50/UA-45 Universal Inline Amplifier. This device is a high-output (45dB+) signal booster that connects between a telephone base and handset. It is a high-power universal inline amplifier designed to provide maximum signal boost for individuals with severe hearing loss. This amplification device incorporates the following: Amplification boost up to 45dB+. Amplification without boost is 30dB+. Tone control to boost low or high frequency speech consonants. Ports to connect the amplifier to the phone and handset. Power supply input. Headset compatibility switch to adapt to various institutional telephone systems. The fourth item concerned is referred to as the SA-40 Cellphone Amplifier. This device is a Bluetooth telephone type handset that wirelessly connects to the user’s cellular telephone. It is used to amplify (40dB+) the audio which is output via its internal speaker. It is stated to be a specialized portable amplifier that pairs via Bluetooth to a mobile phone to provide amplified audio for the hard-of-hearing. It functions as a high-output "handset" or speakerphone for mobile calls. It additionally has T-Coil compatibility to connect directly to T-Coil enabled hearing aids. This device incorporates the following: Speaker Talk button (pickup call). Mute button. Mode selector to select between Handset (HS), T-Coil (T), Speaker (SPKR). On/Off switch. Volume buttons. Tone control to select between Lo, Mid, and High Speech frequency. USB-C charging port. External headset connection. T-Coil signal receiver. In your request, you suggest that the correct classification for the UA-30 Handset Amplifier and the SA-40 Cellphone Amplifier should be in subheading 8518.40.2000, HTSUS, which provides for “…audio-frequency electric amplifiers….”. We disagree. The UA-30 Handset Amplifier and the SA-40 Cellphone Amplifier are not solely audio frequency electric amplifiers, they also incorporate microphones and speakers. They are an amplified loudspeaker assembly. The explanatory notes to heading 8518, HTSUS, explain that loudspeakers may incorporate digital to analogue converters, matching transformers and amplifiers. As such, these products would not be classified as if they only consisted of an audio-frequency electric amplifier. Subheading 8518.40.2000, HTSUS would not be applicable for these products. The applicable subheading for the HD-40P Amplified Telephone will be 8517.18.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks: Other: Other.” The general rate of duty will be Free. The applicable subheading for the UA-30 Handset Amplifier and the SA-40 Cellphone Amplifier will be 8518.21.0000, HTSUS, which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Loudspeakers, whether or not mounted in their enclosures: Single loudspeakers, mounted in their enclosures.” The general rate of duty will be Free. The applicable subheading for the UA-50/UA-45 Universal Inline Amplifier will be 8518.40.2000, HTSUS, which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Audio-frequency electric amplifiers: Other.” The general rate of duty will be Free. In your submission for all four items concerned, you requested consideration of a secondary classification under 9817.00.96, HTSUS, which applies to articles and parts 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, 89

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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division