N365345

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365345 October 8, 2026 CLA-2-83:OT:RR:NC:N5:121 CATEGORY: Classification TARIFF NO.: 8302.10.6030 James Matz C.H. Robinson Worldwide, Inc. 1701 Golf Road, Tower 1, 8th Floor Rolling Meadows, IL 60008 RE: The tariff classification of steel swing clear hinges from China Dear Mr. Matz: In your letter dated September 23, 2026, you requested a tariff classification ruling. The two items under consideration are described as 3-1/2” Swing Clear Hinges. Both styles are made of steel and consist of two hinge leaves bent at 90 degrees that are connected by a removable hinge pin. Item number S3558SW has a 5/8" radius corner and item number S3514SW has a 1/4" radius corner. These are a type of offset hinge that is designed to allow the door to open completely outside the door jamb so that the full width of the opening is available for passage for easy access for persons using wheelchairs or walkers. You stated that these hinges can convert doorways otherwise not compliant with the 32-inch minimum clearance of Section 404.2.3 of the ADA Standards for Accessible Design, which measures clearance width between the face of the door and the stop, when the door is open at 90 degrees. Each style is sold as a single hinge. The applicable subheading for the 3-1/2 inch Swing Clear Hinges, Item numbers S3558SW and S3514SW will be 8302.10.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork… Hinges and parts thereof: Of iron or steel, of aluminum or of zinc: Other, Suitable for interior and exterior doors (except garage, overhead or sliding doors). The general rate of duty will be 3.5 percent ad valorem. In your submission you also 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, 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 the chronically handicapped so that the article is easily distinguishable from articles useful to the general public and any use thereof by the general public is so improbable that it would be fugitive; (3) whether articles are imported by manufacturers or distributors recognized or proven to be involved in this class or kind of articles for the handicapped; (4) whether the articles are sold in specialty stores which serve handicapped individuals; and, (5) whether the condition of the articles at the time of importation indicates that these articles are for the handicapped. In analyzing the 5 factors, this office finds the Swing Clear Hinges are not easily distinguishable by a specific design or form when compared to similar hinges for use by non-handicapped persons or the general public. The use of the Swing Clear Hinges by non-handicapped persons as well as the general public is not so improbable that it would be fugitive. A search of marketing and advertising resources do not limit the sale of similar Swing Clear Hinges exclusively from specific manufacturers to distributors and retailers. Swing Clear Hinges are available for purchase by the general public. The factors do not weigh in favor of a determination that the Swing Clear Hinges are “specially designed” for the use or benefit of persons with chronic and reduced mobility to an extent greater than for the general public and do not satisfy the 5 factors set out by CBP. As a result, it is the opinion of this office that a secondary classification will not apply in subheading 9817.00.96, HTSUS. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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) an

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 Jennifer Jameson at jennifer.d.jameson@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division