
The "Access Code" for Medical Device Classification
As a seasoned veteran in foreign trade, I often encounter clients holding medical device products with a puzzled look, asking, "Which HS code does this actually fall under?" Due to their cross-industry nature, medical devices...Classification of CustomsTime is like solving a complex multivariate equation. Today, let's decipher the "clearance code" of medical devices together through several typical cases.
Diagnostic Equipment: The Dual Identity of Electronic Ultrasonic Endoscopes
I remember in 2018, when acting as an agent for importing a batch ofelectronic ultrasonic endoscopesthe customer insisted on declaring them as optical endoscopes. After carefully studying the product description, we found that:
- It has both optical imaging and ultrasonic imaging functions
- Ultrasonic diagnosis is its main function
- It meets the description of tariff item 90.18 "electrical diagnostic apparatus".
Finally, according to9018.1291The declaration passed customs smoothly. This case tells us that when classifying medical devices, we should graspThe main functionThis "bull's nose."
Medical Equipment: The "Complete Set" Mystery of Infusion Pumps
Last year, a customer made a joke when importing an infusion pump: declaring the main unit and consumables separately, and was finally required by the customs to pay additional taxes. Here is a key knowledge point:
- When imported as a set, it is classified as a complete set of goods9018.3900
- When imported separately, it is still classified under the same tariff number as similar products of syringes
- The packaging status determines the classification method
Just like you cant bring only half a photo on a blind date, thecomplete statusof medical devices directly affects the classification result.
Monitoring Instruments: The "Mind-Reading" of EEG Systems
There was an import case of a neurology device that impressed me deeply: a 128 - leadelectroencephalogram systemwas initially misclassified as a computer - related product. We demonstrated the correct classification from three aspects:
- Specifically used for the collection and analysis of cranial nerve electrical signals
- Conforming to the definition of electroencephalographs in tariff item 9018
- Even when connected to a computer, it does not change itsMedical Devicesessence
Finally, it was classified into9018.1990. This case confirms the golden rule of medical device classification:Purpose determines classification.
Implantable Device: The "ID Card" of Artificial Joints
When declaring a batch ofartificial knee joint componentshandled this year, we especially emphasized:
- It is necessary to provide the YY0117.3 industry standard certificate
- Clearly indicate the intended use as "surgical implants".
- Completely describe the function of the component in the system
These "identity proofs" help products to be accurately categorized.9021.3100. Remember: The classification of implantable devices is like applying for a visa, andsupporting materialsare indispensable.
Teaching Equipment: The "Soul-Searching" of First Aid Manikins
Recently, there is an interesting case:Interactive First Aid Simulation SystemThe analysis software was missing during import. We successfully classified it according to General Rules for the Interpretation of Customs Tariff II (incomplete goods are classified as complete goods).9023.0090Here is an important revelation:
- The silicone main body already has basic characteristics.
- The teaching purpose is clear.
- The sensor configuration determines the functional attributes.
Medical device classification sometimes requires "observation, auscultation, inquiry, and palpation" to grasp the essence of the product.essential characteristicsis the key.
Guide to Avoiding Pitfalls in Medical Device Classification
Combined with 20 years of agency experience, I have summarized theThree Disciplines and Eight Points for Attention in the classification of medical devices.:
- Three Disciplines:
- The principle of giving priority to function and use
- The principle of declaring in a complete state
- The principle of having necessary standard certificates
- Eight Points for Attention:
- Pay attention to the subordinate relationship of combined devices.
- Pay attention to the matching status of consumables and the main unit.
- Pay attention to the timeliness of industry standards.
- Pay attention to the standardization of product names.
- Pay attention to the complete function of components.
- Pay attention to the correlation between software and hardware.
- Pay attention to the particularity of medical uses.
- Pay attention to the reference value of classification decisions.
Classifying medical devices is like dancing the tango—you need to understand both the "partner" of product characteristics and the "steps" of tariff rules. May these practical cases help you perform an elegant "classification dance" on the international trade stage.