The tariff classification of liquid chromatography columns from Japan
Active· CBP ruling HQ N350390· Issued 2025-07-08
Ruling text
N350390 July 8, 2025 CLA-2-84:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 8421.29.0065; 9903.01.25 Shinji Azuma Amuza Inc. 10060 Carroll Canyon Rd, Suite 100 San Diego, CA 92131 RE: The tariff classification of liquid chromatography columns from Japan Dear Mr. Azuma: In your letter dated June 18, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The items under consideration are described as Eicom High-Performance Liquid Chromatography (HPLC) columns entered under model numbers CA-5ODS, SC-5ODS, CAX, PP-ODS3, AC-GEL, AC-ENZYMPAK2, NO-PAK, and GU-GEL. The columns are designed to separate molecules based on their chemical properties and then detect the separate molecules using electrochemical reactions. The columns contain a stationary phase that interacts with the sample components, while the mobile phase carries the sample through the column. Eicom systems are known for their high sensitivity and are frequently used in neuroscience research for neurotransmitter detection. In your letter, you have provided eight different HPLC columns for review. The first column is the CA-5ODS, which is a reverse-phase separation column. The packed material is octadecylsilane-bonded porous silica gel with a 5 micrometer diameter. CA-5ODS is suitable for the separation of catecholamine analysis in an extract. The second column is the SC-5ODS, which is a reversed-phase separation column. The packed material is octadecylsilane-bonded porous silica gel with a 5 micrometer diameter. SC-5ODS is suitable for the separation of monoamines and other biological samples. The third column is the CAX, which is a 5 micrometer silica gel ion exchange column. The CAX retains and separates cations, which are ions with a positive electrical charge, formed when an atom or molecule loses one or more electrons. Many monoamine metabolites found in brain microdialysis samples are anionic at neutral pH, and therefore, not easily retained on the column. It is therefore possible to get a clean chromatogram of only the monoamines when using HPLC with electrochemical detection (ECD). The fourth column is the PP-ODS3, which is a reversed-phase octadecylsilane bonded porous silica gel column. EICOMPAK PP-ODS3 is suitable for the separation of dopamine and serotonin. The fifth column is the AC-GEL, which is packed with a polymer resin and used for the analysis of acetylcholine (ACh). It separates Choline (Ch) from the solvent front and homocholine (HCh) from ACh. The sixth column is the AC-ENZYMPAK2, which is an immobilized enzyme column used for the analysis of choline and acetylcholine. The column contains two enzymes, choline oxidase (EC1.1.3.17) and acetylcholinesterase (EC3.1.1.7). The conversion efficiency is 100% due to the amount of immobilized enzyme that is present. The seventh column is the NO-PAK, which is a separation column used to separate nitrogen dioxide (NO2) and nitrate ions (NO3) in biological samples. The separation mechanism is reversed-phase chromatography and is packed with a polystyrene resin. This column is for use with Eicom’s nitric oxide analysis systems, ENO-20 and ENO-30. The eighth column is the GU-GEL, which is a polymer resin-based column that can be used with a wide range of PHs, except for strong acids and alkaline PHs. The column has been developed for analyzing glutamate with an immobilized enzyme column. In your letter, you suggest the Eicom HPLC columns to be classified under 9027.90.8400, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis 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 or light (including exposure meters); microtomes; parts and accessories thereof: Microtomes; parts and accessories: Parts and accessories: Other: Other: Of instruments and apparatus of subheading 9027.20, 9027.30, 9027.50, 9027.81 or 9027.89.” We disagree. While the columns are used with liquid chromatographs, they are themselves an article that is solely used for liquid separation. The Eicom HPLC columns perform the separation and do not involve any synthesis or chemical reaction within the column itself. Chapter 90 Note 2(a) states: Parts and accessories which are goods included in any of the headings of this chapter or of chapter 84, 85 or 91 (other than heading 8487, 8548 or 9033) are in all cases to be classified in their respective headings. Since the function of liquid separation is covered by heading 8421, HTSUS, they would appropriately be classified in that heading. Additionally, the Eicom HPLC columns are very similar to the SiliaChrom XT C18 HPLC Column in New York Ruling Letter N102164 (dated May 19, 2010). The column was also used with chromatography equipment and for the separation of liquids. Accordingly, the applicable subheading for the Eicom HPLC columns (model numbers CA-5ODS, SC-5ODS, CAX, PP-ODS3, AC-GEL, AC-ENZYMPAK2, NO-PAK, and GU-GEL) will be 8421.29.0065, HTSUS, which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: Other: Other: Other: Other.” The general rate of duty will be free. 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 from all countries will be subject to an additional 10 percent ad valorem rate of duty. 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 8421.29.0065, HTSUS, listed above. The tariffs and additional 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/. 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) 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division
Source: rulings.cbp.gov — ruling N350390, retrieved 2026-10-12T06:04:57Z, republished verbatim. This digest is informational; only CBP issues binding rulings.