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NY 864354




July 15, 1991

CLA-2-90:S:N:N1:119 864354

CATEGORY: CLASSIFICATION

TARIFF NO.: 9018.90.8000

Mr. Jerrold E. Anderson
Katten Muchin & Zavis
525 West Monroe Street - Suite 1600
Chicago, IL 60606-3693

RE: The tariff classification of Injection Site Connector Sets from Singapore.

Dear Mr. Anderson:

In your letter dated June 12, 1991, you requested a tariff classification ruling on behalf of Baxter Health Care Corporation.

The three samples on which you have requested a ruling are the following:

(1) the IV Connector Loop which consists of an injection site, 4
1/2 inches of plastic tubing, and a male Luer slip adapter and cap

(2) the T-Connector which consists of a two-way ("T") housing with one
(your letter states two) injection site, 5 1/2 inches of plastic tubing, a slide clamp, and a Luer adapter with cap

(3) the Microbore Extension set which consists of plastic tubing in a "Y" configuration with two injection sites, two slide clamps and a Luer adapter.

The injection sites of all three sets have a slit rubber membrane that can be penetrated by a "pointed tube connector". This plastic article is 3/4 of an inch long and consists of a Luer lock adapter at one end and a thin piece of tubing at the other that measures approximately 1/16 of an inch in diameter at its tip. This "pointed tube connector", that you call a cannula, is too dull to puncture a person's skin, thus constituting a safe alternative to a hypodermic needle which can also be used with these injection sites. The main purpose of the system is to eliminate the danger of infection from needle pricks, but the system can also be used in place of Luer lock connectors.

You have assumed that the "pointed tube connector" is classifiable as a "cannula" and you are of the opinion that these connector set samples incorporating the special injection sites are accessories of the "cannula" and should therefore be classified under subheading 9018.39.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for syringes, needles, catheters, cannulas and the like; parts and accessories thereof ... other.

An accessory is defined as "a subordinate or supplementary part, object, etc., as an automobile spotlight or a camera tripod." See the Random House College Dictionary (Revised Edition). It is difficult to rationalize or even perceive these Injection Site Connector Sets as accessories of the "pointed tube connector". It might be more appropriate to consider the "pointed tube connector" as an accessory of the Injection Site Connectors. However the classification of this "pointed tube connector" will not be dealt with in this letter since you did not request a ruling on this article.

The three connector set samples are used principally with and are parts or accessories of IV administration sets.

The applicable subheading for the three Injection Site Connector Sets will be 9018.90.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for instruments and appliances used in medical, surgical, dental or veterinary sciences ... parts and accessories thereof ... other. The rate of duty will be 7.9 percent.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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