N360974

N360974May 19, 2026CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification; Country of Origin; MarkingSteven SandersSanders Brokerage Services1050 B Street - Bldg. B STE #1P.O. Box 1983Blaine, WA 98231RE: The classification, country of origin and marking of a smart horse sneakerDear Mr. Sanders:In your letter dated April 23, 2026 , on behalf of your client, Cavallo Horse and Rider LLC, you requested aclassification, country of origin, and marking ruling on a smart horse sneaker. Descriptive literature wasprovided for our review.The item under consideration is described as the Consteed Smart Horse Sneaker, which is an advanceddiagnostic equine boot designed to detect early lameness in horses through comprehensive gait andmovement analysis. Intended for veterinarians, trainers, farriers, and rehabilitation professionals, this systemcomes as a kit comprising four smart horse sneakers, a multi-connection charger, a hoof pick, and four hoofsocks. Each hoof boot integrates embedded electronic sensors, including force sensors, in the sole to recordpressure distribution and an Electronic Unit (EU) that captures 6-axis movement and acceleration values.This data, collected directly from the horse’s hoof, is transmitted wirelessly via Bluetooth to a paired mobiledevice. Utilizing a combination of force-plate technology, pressure mapping, and motion-sensor electronics,the Consteed Smart Horse Sneaker measures ground reaction forces (measured in Newton) and processes thisinformation to provide real-time, quantitative insights into the horse’s gait, balance, and symmetry. Thisenables the early identification of potential sources of lameness. The Consteed Smart Horse Sneaker isspecifically for diagnostic assessment and is not intended as a riding boot, protective hoof boot for turnout, orfor equine protection or hoof therapy.The Consteed Smart Horse Sneaker is assembled from components sourced globally, including Luxembourg,Switzerland, Austria, Indonesia, China, Italy, Liechtenstein, and Germany. Indonesia provides the hoof boot,hoof socks, and holder. Chinese components include the ECU battery, hoof pick, magnet, and RFID label.Italy supplies a significant portion of the system, including the electronic unit (ECU), sensors, contactcharging pin, USB-A with printed circuit board, cover plate, organ plate, case, banderole, charging cable,quick start guide, safety regulation booklet, and various labels. From Luxembourg comes the Sensor SZ L, which includes adhesive film, while other minor components are sourced from Switzerland. Liechtensteinprovides the sensor mat, and Austria contributes the sensor plate, including its RFID and cover plate. Finally,Germany supplies the polyurethane coating, additional labels, and pressure equalization membranes.The hoof boot manufacturing occurs in Indonesia starting with the injection molding of the lower hard-shellhousing from a polycarbonate and acrylonitrile butadiene styrene (PC+ABS) blend. After inspection, two flatdisc magnets are press-fitted into the housing before press-fitting the charging clip electronics with cableassembly into the lower housing. Simultaneously, the upper charger housing is injection-molded fromcustomized thermoplastic elastomers (TPE). The complete charger assembly is then tested using a testfixture, with defective parts removed.The hoof boot is then sent to Italy along with the Chinese battery, and the sensor mat from Liechtenstein. InItaly, the manufacturing process begins with the injection molding of fiber optics, rear covers, and frontfaces, including the installation of PTFE membranes, charging pins, and magnets. After inspections,electronics are prepared via sensor/RFID integration and plasma treated cover plates, accompanied by ECUflashing, The next process includes the AD converter calibration, and thermal conditioning of the sensors. Peryour letter, the sensors are manufactured, programmed, and calibrated in Italy. Each of the assembliesundergo hydraulic calibration, ultrasonic welding, and functional testing to ensure proper componentintegration. The process concludes with packing, labeling, and preparing the final product for shipment.CLASSIFICATIONIn your letter, you suggest the applicable subheading for the Consteed Smart Horse Sneaker to be 9027.89.80,Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatusfor physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smokeanalysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion,surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound orlight (including exposure meters); microtomes; parts and accessories thereof: Other instruments andapparatus: Other: Other: Other.” We disagree. The Consteed Smart Horse Sneaker is designed to use sensorsto test whether the horse’s weight is distributed properly. This in turn helps monitor the musculoskeletalsystem of the horse. The device is performing more of a checking function of the mechanical and physicalproperties like step accuracy, force distribution, and balance, which are not similar to the analysis of physicalproperties defined by heading 9027. While gait analysis involves “physical” movement, it is not “physicalanalysis” of a material’s properties in the sense intended by heading 9027. Additionally, the device is notmeasuring surface tension as suggested in your letter. Measuring the way a horse moves (biomechanics) isconsidered a “checking” function of mechanical movement more akin to the products classified in heading9031. Accordingly, heading 9027 is excluded from consideration.The applicable subheading for the Consteed Smart Horse Sneaker will be 9031.80.8085, HTSUS, whichprovides for “Measuring or checking instruments, appliances and machines, not specified or includedelsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances andmachines: Other: Other.” The general rate of duty will be free.ORIGINWhen determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether asubstantial transformation will occur is whether an article emerges from a process with a new name,character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).Regarding the origin of the Consteed Smart Horse Sneaker, we find that the device is not able to operate untilall components are gathered and assembled in Italy. The Indonesian hoof boot and sensor mat from Liechtenstein are transformed into a new article with name, character, and use different from the individualcomponents. Without the additional Italian components, including the ECU, sensors, and manufacturing, thehoof boot would serve no purpose, and the sensor mat could not provide readings. Therefore, in our opinion,the origin of the Consteed Smart Horse Sneaker is Italy, which is where the individual components become aworking force sensor measuring device.MARKINGSection 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, everyarticle of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as toindicate to the ultimate purchaser in the United States, the English name of the country of origin of thearticle. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able toknow by an inspection of the marking on the imported goods the country

(for example, polarimeters, refractometers, spectrometers, gas or smokeanalysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion,surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound orlight (including exposure meters); microtomes; parts and accessories thereof: Other instruments andapparatus: Other: Other: Other.” We disagree. The Consteed Smart Horse Sneaker is designed to use sensorsto test whether the horse’s weight is distributed properly. This in turn helps monitor the musculoskeletalsystem of the horse. The device is performing more of a checking function of the mechanical and physicalproperties like step accuracy, force distribution, and balance, which are not similar to the analysis of physicalproperties defined by heading 9027. While gait analysis involves “physical” movement, it is not “physicalanalysis” of a material’s properties in the sense intended by heading 9027. Additionally, the device is notmeasuring surface tension as suggested in your letter. Measuring the way a horse moves (biomechanics) isconsidered a “checking” function of mechanical movement more akin to the products classified in heading9031. Accordingly, heading 9027 is excluded from consideration.The applicable subheading for the Consteed Smart Horse Sneaker will be 9031.80.8085, HTSUS, whichprovides for “Measuring or checking instruments, appliances and machines, not specified or includedelsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances andmachines: Other: Other.” The general rate of duty will be free.ORIGINWhen determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether asubstantial transformation will occur is whether an article emerges from a process with a new name,character, or use different from