In ruling NY N311303, Customs and Border Protection (CBP) discussed the classification of a laser hair therapy system from China. It is comprised of a helmet-shaped dome housing which is incorporated with 51 laser diodes and 30 LEDs. The system further consists of a foam pad, safety sensors, a power wire, and remote control. The system is used in the home to promote hair growth in men and women.

In use, the device is placed on the user’s head. The lasers and LEDs emit light energy that works to stimulate the hair follicles to promote growth and reactivate dormant growth areas of the scalp. These units are not meant to be used by medical professionals, but instead are only used by individuals in their home.

CBP determined that the applicable subheading for the laser hair therapy system is 9013.80.9000, HTSUS, which provides for “Liquid crystal devices…: Other devices, appliances and instruments: Other.” The general rate of duty will be 4.5% ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9013.80.9000, HTSUS, unless specifically excluded, are subject to an additional 7.5% ad valorem rate of duty. At the time of importation, the Chapter 99 subheading, 9903.88.15, in addition to subheading 9013.80.9000, HTSUS, must be reported.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

Read more about Frances P. Hadfield
Show more Show less
Related Posts
Update on Parallel Federal Court Cases Enjoining IEEPA
June 6, 2025
District Court Denies Motion to Move Venue, Grants Preliminary Injunction
May 29, 2025
Court of International Trade Blocks IEEPA Tariffs
May 28, 2025