Announcement on the Release of the Decision on Commodity Classification in 2025: Key Points Explained

 

 

To facilitate importers, exporters, and their agents in correctly declaring the commodity classification of imported and exported goods, and in accordance with the relevant provisions of the Regulations of the People's Republic of China on the Administration of Commodity Classification of Import and Export Goods (Order No. 252 of the General Administration of Customs of the People's Republic of China), the General Administration of Customs has recently issued the 2025 Decisions on Commodity Classification. The key points of such decisions are interpreted below.

I. Mozzarella Cheese Block

 

Ruling No.	Z2025-0001	HS code	0406.1000
Commodity Name	Mozzarella Cheese Block	Specifications	Retail Packaging
Product Description	Mozzarella cheese block with a moisture content of 48% and a fat content of 21.3g per 100g. Ingredients: Pasteurized cow’s milk (98.757%), edible salt (1.0%), Streptococcus thermophilus culture (0.2%), calcium chloride (0.04%), rennet (0.003%). Manufacturing process: 1. Pasteurization of fresh cow’s milk; 2. Inoculation with Streptococcus thermophilus culture for fermentation and acidity adjustment; 3. Adding rennet to induce coagulation, and cutting of the resulting curd; 4. Mixing with water and stretching into filamentous strands; 5. Salting and stirring, followed by molding, then cooling to 10°C, and finally vacuum packaging; 6. It is then stored at 0-4°C for 10 days before shipment. Storage method: Store at or below -18°C in a frozen state.
Classification Ruling	The product meets the description of "fresh cheese" intended for consumption within a short period after production, as outlined in the Explanatory Notes to Heading 04.06. According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, this kind of product is classified under HS code 0406.1000.

 

The Explanatory Notes to Heading 04.06 define "fresh cheese" in its first paragraph as "an unripened or uncured cheese intended for consumption within a short period after production (e.g., cottage cheese, Broccio, unfermented cheese, cream cheese, unsalted cheese)". Among the listed varieties, "unsalted cheese" corresponds to "Mozzarella".

“Mozzarella” (also known as Mozzarella cheese) is a fresh cheese originating from southern Italy, traditionally made from water buffalo’s or cow’s milk. Its primary production process comprises the following key steps: preprocessing of raw milk (pasteurization, standardization); fermentation and coagulation; whey drainage and pre-pressing; hot stretching; molding and cooling; as well as final packaging.

The subheading 0406.10, "Fresh cheese (unripened or uncured)," means that the cheese has not undergone an aging process, and thus typically remains fresh and moist.

The product is manufactured through specific steps, including salting, stirring, molding, cooling, and a 10-day storage period at low temperature. These steps serve to reduce moisture content (thereby achieving proper shaping), enhance meltability and stretchability, and improve storage stability. These functional properties render it suitable for culinary applications such as pizza topping or general cooking. It is important to note that these steps do not equate to an “aging” (ripening) process. Consequently, the manufacturing process of this product remains within the recognized scope of processing for “fresh cheese” and does not alter its essential character. According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, this kind of product is classified under HS code 0406.1000.

II. Narwhal Tusk

 

Ruling No.	Z2025-0002	HS code	0507.1000
Commodity Name	Narwhal Tusk	Specifications	1.5-2.5 meters per tusk
Product Description	Narwhal tusk, imported in its whole form, undergoes the following processes: 1. Soaking in water at room temperature for one day, followed by immersion in hot water at 90°C for 60 minutes to remove residual flesh and blood; 2. Soaking in hydrogen peroxide solution for one day, then scrubbing with a steel brush and rinsing with water; 3. After drying, soaking in a cresol-based disinfectant solution (commonly known as "Lysol") for one day, followed by rinsing, cleaning, and coating with concentrated brine; subsequent rinsing and air-drying in a dry, ventilated area for 3-5 days until fully dehydrated; 4. Application of petroleum jelly to further isolate the tusk from moisture and air, thereby achieving a preservative effect.
Classification Ruling	The narwhal tusk is a product specifically listed as “narwhal (Monodon monoceros) tusk” in Note 3 to Chapter 5 of the Tariff and, correspondingly, under Heading 05.07 of the Explanatory Notes. The processing steps it has undergone, including cleaning, removal of flesh and blood, drying, and application of petroleum jelly, constitute “simply prepared but not cut to shape”as defined for that heading. This definition specifies that no further working is permitted other than operations such as filing, scraping, washing, removal of superfluous parts, finishing, splitting, cutting to length, rough planing, straightening, or flattening. Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, this kind of product is classified under HS code 0507.1000.

 

The narwhal tusk, imported in its whole form, has undergone processing steps including chemical soaking, soft tissue removal, scrubbing with a steel brush, drying, dehydration, and the application of petroleum jelly. It is intended primarily for subsequent processing or for collection and display.

The product corresponds precisely to "narwhal (Monodon monoceros) tusk" as specifically listed in Note 3 to Chapter 5 of the Tariff and under Heading 05.07 of the Explanatory Notes. Critically, the processing applied falls within the definition under Heading 05.07, which explicitly limits allowable processing to operations such as filing, scraping, washing, removal of superfluous parts, finishing, splitting, cutting to length, rough planing, straightening, or flattening, and prohibits any further working. Consequently, it meets the legal definition of “unworked or simply prepared but not cut to shape”. As such, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified as animal ivory under HS code 0507.1000.

III. Cinnamomum tamala Leaves (Indian Bay Leaves)

 

Ruling No.	Z2025-0003	HS code	0910.9990
Commodity Name	Cinnamomum tamala Leaves (Indian Bay Leaves)	Specifications	Bulk
Product Description	Leaves of the Cinnamomum tamala tree possess a pungent, cinnamon-like aroma. They are primarily used as a traditional edible spice in South Asia, with an additional use in essential oil extraction.
Classification Ruling	Cinnamomum tamala (commonly known as Indian Bay), a member of the Lauraceae family, is classified under HS code 0910.9990, in accordance with Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System.

 

The plant Cinnamomum tamala, a member of the Lauraceae family, is specifically listed under Heading 09.06 “Cinnamon” in the Explanatory Note. It is important to note that Heading 09.06 exclusively covers “cinnamon” defined as the inner bark of the tree’s shoots, and does not include its leaves.

Heading 09.10 covers “Ginger, saffron, turmeric (curcuma), thyme, bay leaves, curry and other spices”. Cinnamomum tamala leaves possess a pungent, cinnamon-like aroma and are used as a traditional edible spice in South Asia, with an additional application in essential oil extraction. Given these characteristics and uses, the leaves clearly fall within the scope of Heading 09.10. Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, the product is classified under HS code 0910.9990.

IV. Feed-Grade Wheat Flour

 

Ruling No.	Z2025-0004	HS code	1103.1100
Commodity Name	Feed-Grade Wheat Flour	Specifications	50 kg/bag
Product Description	Composition: 80% wheat flour, 20% barley flour. Laboratory analysis yields the following results (on a dry weight basis): ash content 2.5 g/100g, and starch content 56.0 g/100g; sieve analysis: 36.5% through 315 μm, and 96.2% through 1.25 mm. No mineral components were detected in the ash.
Classification Ruling	In accordance with Note 2(a) to Chapter 11 of the Tariff, the maximum permissible ash content for this mixture is calculated as (80% × 2.5%) + (20% × 3%) = 2.6%. The minimum required starch content is calculated as (80% × 45%) + (20% × 45%) = 45.0%. The tested values for ash and starch of this product comply with these Chapter-level criteria, thus confirming its classification within Chapter 11. Furthermore, the product meets the sieve test requirements specified for “groats and meal”under Notes 2(b) and 3 to Chapter 11 of the Tariff. Given that wheat constitutes 80% of the product and thereby imparts its essential character, the commodity is classified under HS code 1103.1100, pursuant to Rule 1, 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System.

 

The classification of products from the milling of the cereals is governed by Note 2 to Chapter 11 of the Tariff. The note 2(a) stipulates that “products from the milling of the cereals listed in the table below fall in this Chapter if they have, by weight on the dry product”:

“1. a starch content (determined by the modified Ewers polarimetric method) exceeding that indicated in Column (2); and 2. an ash content (after deduction of any added minerals) not exceeding that indicated in Column (3). Otherwise, they fall in 23.02.”

The product is a mixture of 80% wheat flour and 20% barley flour. However, note 2(a) to Chapter 11 specifies ash content limits only for individual (unmixed) cereals. Therefore, for this mixture, the permissible ash content limit must be calculated as a weighted average based on the respective proportions. The calculation for ash content is: (2.5% for wheat × 80%) + (3.0% for barley × 20%) = 2.6%. As for starch content, the specified limit is 45% for each of the constituent cereals (wheat and barley). Consequently, this 45% limit applies unchanged to their mixture.

Its tested values - ash content 2.5g/100g and starch content 56.0g/100g - comply with the requirements of Note 2(a) to Chapter 11 (i.e., starch content exceeding 45%, and ash content, after deduction of any added minerals, not exceeding the calculated limit of 2.6%). Therefore, the product is classifiable within Chapter 11.

In addition, the product's 36.5% passing rate through 315 μm does not meet the criteria for “flour” as specified in Note 2(b) to Chapter 11, whereas its 96.2% passing rate through 1.25 mm does meet the criteria for “groats and meal” as specified in Note 3 to Chapter 11. Consequently, it falls under Heading 11.03.

As the wheat accounts for 80% of the product and thereby imparts its essential character, the product is classified under HS code 1103.1100, pursuant to Rule 1, 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System.

V. Agarwood Chips

 

Ruling No.	Z2025-0005	HS code	1211.9050
Commodity Name	Agarwood Chips	Specifications	Bulk
Product Description	Dimensions: 35 cm (L) × 10 cm (W) × 0.8 cm (T), with holes through the central section. The wood is processed by cutting away the non-resinous sapwood (the “white wood”) and then sanding it, thereby retaining the resin-rich outer heartwood and forming it into flat chips.
Classification Ruling	The product is processed into flat chips by cutting away the non-resinous sapwood and sanding the material, thereby retaining the resin-rich outer heartwood (i.e., the valuable agarwood portion). It is intended primarily for use as incense or a perfume ingredient. These characteristics align with the scope of Heading 12.11 as described in the Explanatory Notes. According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, the product is classified under HS code 1211.9050.

 

Agarwood chips are processed into flat chips through the following steps: the non-resinous sapwood (the “white wood”) is cut away; the resin-rich outer heartwood (i.e., the valuable agarwood portion) is retained; and the material is sanded. It is intended primarily for use as incense or a perfume ingredient.

These characteristics (its form and intended use) meet the requirements set out under Heading 12.11 as outlined in the Explanatory Notes: “Wood, in chips, in shavings, crushed, ground or powdered, of a kind used primarily in perfumery, in pharmacy, or for insecticidal, fungicidal or similar purposes”. The classification is therefore based on three key factors: I. its physical form (flat chips); II. its composition (the resin-rich heartwood); and III. its intended use (as incense or a perfume ingredient). Consequently, the product is classified under HS code 1211.9050, pursuant to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System.

VI. Three-Way Stopcock (for Infusion)

 

Ruling No.	Z2025-0006	HS code	8481.8029
Commodity Name	Three-Way Stopcock (for Infusion)	Specifications
Product Description	The device consists of a handle, a male Luer lock connector (end cap), a female Luer lock port (structural fitting), a nut, a housing, and a marking plug. It is used to connect and control fluid lines in medical applications such as intravenous infusion and invasive pressure monitoring. When all three lines are connected, the central handle allows fluid entering through one inlet port to be directed to either of the two outlet ports.
Classification Ruling	The product is a manually operated directional control valve used to divert fluid flow in infusion systems; it is not designed for use in hydraulic power transmission systems. Furthermore, it is supplied independently, not as part of a set with medical tubing or catheters. Therefore, it does not meet the criteria for classification as a medical instrument under Heading 90.18. This conclusion is reinforced by Note 1(g), which explicitly excludes the valves and other appliances of heading 84.81 from Chapter 90. Therefore, the product is primarily classifiable under Heading 84.81. With reference to the definition of “solenoid-operated directional control valve” in the domestic heading explanation notes for 8481.8021, and in accordance with Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, the product is classified under HS code 8481.8029.

 

The three-way stopcock (for Infusion) is a medical fluid management device intended for applications such as intravenous infusion. It is designed to connect three lines simultaneously. Flow from a single inlet is manually directed to either of the two outlets via a central handle. It is supplied without and operates independently of medical catheters or tubing.

Classification at the Heading Level: the product is used to manually switch the direction of fluid flow within a line, that is, to close one fluid outlet while opening another. Based on this function, it is regarded as a valve falling within Heading 84.81. Although designed for a medical application, its classification is governed by the legal principle established in Note 1(g), which explicitly excludes “… (g)…valves and other appliances under heading 84.81” from Chapter 90. Therefore, it should not be classified as a medical instrument under Heading 90.18.

Classification at the Subheading Level: Referring to the domestic heading explanation notes for 8481.8021, which describes a directional control valve based on “driving the valve spool movement to change the direction of fluid flow”, the product constitutes a directional control valve. As it is not used in hydraulic power transmission systems, the condition specified in heading explanation note 3 for mandatory classification under subheading 8481.20 is not met. Accordingly, it should be classified under HS code 8481.8029 (“Other directional control valves”) according to the tariff schedule.

VII. Miniature All-Terrain Vehicle (ATV)

 

Ruling No.	Z2025-0007	HS code	8703.1011
Commodity Name	Miniature All-Terrain Vehicle (ATV)	Specifications	100 cm × 57 cm × 52 cm
Product Description	A battery-powered, four-wheeled vehicle bearing an “ATV” identifier on its external packaging. It is capable of operation on various surfaces including sand, grass, and snow. Key features include: handlebar steering; a straddle seat (without a passenger seat); chain-drive transmission; a direct mechanical steering linkage; and off-road, low-pressure knobby tires. It is designed for riders aged 8 and above (max. weight 50 kg) and can reach a top speed of 22 km/h.
Classification Ruling	Pursuant to GB 6675.2-2014 Safety of toys - Part 2: Mechanical and Physical Properties, which sets a maximum speed of 8 km/h for electric ride-on toys, this vehicle (with a maximum speed of 22 km/h) does not comply with the stipulated safety requirements for toys. Therefore, it should not be classified as a ride-on toys under Heading 95.03. Conversely, its intended use, drive mechanism, seating configuration, steering system, and tire specification all correspond to the criteria for “all-terrain vehicles” as set out in the domestic heading explanation notes for HS code 8703.1011. Consequently, the product is classified under HS code 8703.1011, pursuant to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System.

 

The product, labeled “Miniature All-Terrain Vehicle” and bearing ATV markings, differs from typical children's ride-on toys in its key attributes: intended use, drive mechanism, seating configuration, steering system, and tire specification.

The Explanatory Notes to Heading 95.03 describe “wheeled toys” as follows: “These toys are usually designed for propulsion either by means of pedals, hand levers or other simple devices which transmit power to the wheels through a chain or rod, or …Other types of wheeled toys may be simply drawn or pushed by another person or driven by a motor”. The notes also mention “Children’s cars powered by a motor”, do not provide any further detailed regulations. In applying these definitions, Customs refers to external safety standards such as GB 6675.2-2014 Safety of toys - Part 2: Mechanical and Physical Properties, which stipulates that the maximum speed for electric ride-on toys shall not exceed 8 km/h. Given that this vehicle's maximum speed is 22 km/h and thus exceeds the national standard limit, it is not regarded as an electric ride-on toys for classification purposes.

The domestic heading explanation notes for HS code 8703.1011 provides the definition and outlines the key characteristics of “all-terrain vehicles”, but its descriptive focus is on those powered by internal combustion engines. In recent years, alongside the rise and technological advancement of electric vehicles, ATVs have increasingly shifted to electric motor powertrains. This can result in a different drivetrain layout and suspension geometry, due to the distinct packaging and layout of electric vehicles compared to internal combustion engine vehicles. Against this backdrop, the vehicle’s overall design, control method, and all-terrain capability are evaluated. Although its specific design does not fully align with the literal wording of the domestic heading explanation notes, its essential nature and function qualify it as an all-terrain vehicle.

VIII. Implantable Left Ventricular Assist System (LVAS) Kit

 

Ruling No.	Z2025-0008	HS code	9021.9090
Commodity Name	Implantable Left Ventricular Assist System (LVAS) Kit	Specifications
Product Description	The product is supplied as a complete medical kit for the treatment of advanced heart failure. It comprises implantable components and accessories, including but not limited to: a centrifugal blood pump; an apical suture ring; an apical coring knife; an outflow graft thread protector; a tunneler adapter; a skin-coring punch; a system controller (including a low-flow 2.0 version) with an emergency backup battery; modular cables; an outflow graft with a curved strain relief ring; and a wearable pouch. It functions as a single-use, implantable centrifugal ventricular assist system, powered electrically to support or replace the heart’s pumping function in the treatment of advanced heart failure.
Classification Ruling	The commodity is a complete system, consisting of implantable components and accessories. It is intended to support or replace the heart's pumping function in the treatment of advanced heart failure. According to Rule 1, 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System, the centrifugal blood pump is identified as the component which imparts the essential character to the entire kit. Consequently, the system is classified under HS code 9021.9090.

 

The Implantable Left Ventricular Assist System Kit, also referred to as the blood pump assembly, is supplied as a complete set. The kit comprises three primary groups of components: (1) long-term implantable parts, including the centrifugal blood pump, outflow graft (artificial blood vessel), apical suture ring, and modular cables; (2) external components, such as the system controller (with power management functions), batteries, battery charger, and associated cables and connectors; and (3) accessories, which include a wearable pouch and specialized surgical tools for implantation. Its clinical function is to create a bypass circuit that diverts blood from the apex of the left ventricle to the ascending aorta, thereby assisting or completely taking over the heart's pumping function in patients with advanced heart failure.

The kit meets the criteria of "goods put up in sets for retail sale" as defined in Rule 3(b) of the General Rules for the Interpretation of the Harmonized System. Consequently, its classification is determined by the component which imparts the essential character to the whole set. The centrifugal blood pump is the component responsible for the core function of moving blood, and therefore it establishes the essential character of the kit.

While the blood pump, by its name, could be considered a "liquid pump" falling under Heading 84.13, its principal and dedicated medical application places it within the scope of Chapter 90 (medical instruments). Since Note 1(m) to Section XVI excludes articles of Chapter 90, this device is precluded from classification in Section XVI and is therefore classifiable in Chapter 90. The Classification Catalogue of Medical Devices defines the function of "Implantable Circulatory Assist Devices" (under "Active Implantable Devices") as being "used to assist ventricular circulatory function or to take over the pumping function of the heart”. According to this definition, the blood pump qualifies as an appliance implanted in the body to compensate for a physiological defect or disability. Therefore, its function meets the description of heading 90.21 of the Tariff. According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, the centrifugal blood pump should be classified under HS code 9021.9090. Consequently, the complete set of goods is also classified under 9021.9090, pursuant to Rule 3(b) of the General Rules for the Interpretation of the Harmonized System.

IX. Walrus Tusk

 

Ruling No.	Z2025-0009	HS code	9601.1000
Commodity Name	Walrus Tusk	Specifications	0.5-1 meter per tusk
Product Description	Walrus tusks, imported in its whole form, undergoes the following processes: 1. using a blade to remove residual gingival tissue at the tooth cervix, and a scaler and probe to remove residual plaque, calculus, and surface stains from the crown.; 2. soaking in a 30% hydrogen peroxide solution for one day to chemically dissolve the periodontal tissue attached to the root and to bleach the entire tooth, followed by boiling in water at 100°C for no less than one hour to further dissolve the periodontal tissue, and then using a blade to scrape off any remaining residual soft (periodontal) tissue at the root; (3) using a high-speed handpiece to remove stained dental hard tissue, followed by shade assessment and the removal of any residual debris; (4) Polishing to a high gloss. Intended Use: for subsequent processing or for collection and display.
Classification Ruling	Walrus tusk is an animal tooth specifically listed in Note 3 to Chapter 5 of the Tariff, as well as in Headings 05.07 and 96.01 of the Explanatory Notes. The polishing process it undergoes is not merely "simply prepared" as defined under Heading 05.07, but is more appropriately described as "worked ivory" under Heading 96.01 of the Explanatory Notes. According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, the product is classified under HS code 9601.1000.

 

Walrus tusks are imported in their whole form. The processing involves steps such as soft tissue removal, chemical soaking, bleaching, and boiling at high temperature, followed by polishing (to a high gloss). They are intended for subsequent processing or for collection and display.

Walrus tusk is a commodity specifically listed in Note 3 to Chapter 5 of the Tariff, as well as in Headings 05.07 and 96.01 of the Explanatory Notes. The processing applied to this product goes beyond operations considered “simply prepared” and specifically includes a polishing process (to a high gloss). Heading 96.01 defines materials as "worked" if their processing has exceeded the level of simple preparation permitted for the relevant raw materials under certain headings (refer to the notes to Headings 05.05 through 05.08). Consequently, this heading covers ivory, bone, tortoise-shell, horn, antlers, coral, mother-of-pearl and other similar materials that have been cut to shape (including into squares or rectangles), polished, or worked into forms such as plates, sheets, or rods by processes like grinding, drilling, milling, or turning. The polishing process applied here, therefore, is not merely "simply prepared" as contemplated under Heading 05.07 and fulfills the criteria for "worked" materials under Heading 96.01 of the Explanatory Notes. Consequently, According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 9601.1000.

X. Frozen Tilapia Skin

 

Ruling No.	J2025-0001	HS code	0303.9900
Commodity Name	Frozen Tilapia Skin	Specifications	Bulk, each whole skin measuring 10-40 cm in length.
Product Description	This product is the complete skin of tilapia (Oreochromis spp.). It is fresh with its characteristic smell, and may have some scales still attached. Processing involves: slaughtering the fish, filleting, removing the skin (with scales), hand-trimming any residual meat, keeping the skin intact, rinsing it three times in clean water, and finally freezing at -18°C. It is intended for human consumption or, upon import, for the production of fish glue and decorative leather.
Classification Ruling	The Explanatory Notes to Heading 03.02 provide that: "Edible fish offal separated from the rest of the body of the fish (e.g., skins, tails, maws (swim bladders), heads and halves of heads (with or without the brains, cheeks, tongues, eyes, jaws, or lips), stomachs, fins, tongues), as well as livers, roes and milt, fresh or chilled, are also classified in this heading." Furthermore, the Explanatory Notes to Heading 03.03 state that "the provisions of the Explanatory Notes to heading 03.02 apply, mutatis mutandis, to the products of this heading." As "Frozen Tilapia Skin" is edible, it constitutes edible fish offal. Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, this commodity is classified under HS code 0303.9900.

 

Tilapia (Oreochromis spp.) is a commonly farmed freshwater fish. The processing of tilapia skin involves: slaughtering the fish, filleting, removing the skin (with scales), trimming any residual meat, keeping the skin intact, rinsing it in clean water, and finally freezing at -18°C. The processed skin is fresh and intact. It is suitable for human consumption and is also used industrially to produce gelatin or decorative leather.

Fish skin is an edible fish offal, specifically listed in Heading 03.02. The Explanatory Notes to Heading 03.02 state: "Edible fish offal separated from the rest of the body of the fish (e.g., skins, tails, maws (swim bladders), heads and halves of heads (with or without the brains, cheeks, tongues, eyes, jaws, or lips), stomachs, fins, tongues), as well as livers, roes and milt, fresh or chilled, are also classified in this heading." Products classified under Heading 03.02 are those preserved fresh or chilled, while frozen products fall under Heading 03.03. The Explanatory Notes to Heading 03.03 further provide that "the provisions of the Explanatory Notes to heading 03.02 apply, mutatis mutandis, to the products of this heading." Consequently, frozen tilapia skin falls within the scope of frozen fish offal under Heading 03.03. According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, frozen tilapia skin is classified under HS code 0303.9900.

Furthermore, pursuant to Note 1(c) to Chapter 3 of the Tariff, fish skin which is "unfit or unsuitable for human consumption by reason of either their species or their condition", as presented, is excluded from this chapter and must be classified elsewhere according to its actual use. For example, fish skin used as an industrial raw material for the production of gelatin or collagen is classifiable under HS code 0511.9119; fish skin intended for use as a biological skin graft (wound dressing) is classifiable under HS code 3005.9090; and fish skin used in leather manufacturing is classifiable under HS code 4103.9090.

XI. Blood Glucose Test Strips

 

Ruling No.	J2025-0002	HS code	3822.1900
Commodity Name	Blood Glucose Test Strips	Specifications
Product Description	This product is a disposable consumable used for the in vitro determination of blood glucose levels. It comprises a reagent (or cover) layer, an electrode layer, and a polymer substrate. The reagent layer features a defined reaction zone coated with the enzyme glucose dehydrogenase. Working Principle: After the user inserts the test strip into the meter and draws a small blood sample using a lancet, the blood is drawn by capillary action into the strip's reaction zone. There, it reacts with the enzyme glucose dehydrogenase, generating a minute electrical current. Then, the current is transmitted through the electrodes in the electrode layer to the meter. The meter thus calculates the blood glucose concentration based on the magnitude of this electrical signal.
Classification Ruling	The reaction zone on the reagent layer of this product is coated with enzyme glucose dehydrogenase for the in vitro determination of blood glucose levels, which meets the description of "diagnostic or laboratory reagents on a backing" under Heading 38.22. It is designed to be used with a blood glucose meter as the reactive element of the test system and is excluded from classification as parts or accessories of the instruments and apparatus for physical or chemical analysis under Heading 90.27. Consequently, According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 3822.1900.

 

This blood glucose test strip comprises a substrate, an electrode layer, and a reagent layer which features a defined reaction zone coated with the enzyme glucose dehydrogenase. It is constructed as a diagnostic or laboratory reagent (enzyme glucose dehydrogenase) supported on a plastic substrate backing. Heading 38.22 of the Import and Export Tariff of the People's Republic of China, which covers "diagnostic or laboratory reagents on a backing", applies to this product. This is consistent with the explanatory note to Heading 38.22 of the Explanatory Notes to the Commodities and Headings of the Customs Import and Export Tariff Schedule, which specify that such reagents "may also be in the form of paper, plastics or other materials (used as backings or support), impregnated or coated with one or more diagnostic or laboratory reagents". Functionally, it serves as a disposable consumable. After the user inserts the strip into a blood glucose meter, the blood is drawn by capillary action into the strip's reaction zone, where an electrochemical reaction takes place to determine the blood glucose level. While the blood glucose test strip is used in conjunction with the meter, it is not classified as parts or accessories of the “instruments and apparatus for physical or chemical analysis” under Heading 90.27.

Therefore, this blood glucose test strip is to be classified as "diagnostic or laboratory reagents on a backing". Consequently, According to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under Heading 38.22, with the specific HS code 3822.1900.

XII. Glass Shower Enclosure

 

Ruling No.	J2025-0003	HS code	7020.0099
Commodity Name	Glass Shower Enclosure	Specifications
Product Description	This product is a glass sliding door unit with a single glass panel frame. It comprises one fixed panel of tempered glass (approx. 299 mm wide), one sliding panel of tempered glass (approx. 600 mm wide), an aluminum frame, a top rail, hinges, door handles, and other hardware, but is supplied without a shower base (tray), top cover, or any shower fixtures. The unit is designed for indoor installation, with the panels resting on the floor. The glass panel frame is secured to the wall by a single-sided aluminum profile, and the sliding door is hinged to this frame. It can be configured in two ways: a single unit installed against a U-shaped (three-walled) alcove, or two units combined to fit an L-shaped (two-walled) corner. In either configuration, it forms a fully enclosed, four-sided shower space.
Classification Ruling	This product is a tempered glass door with metal fittings. It's essential character is that of a glass article, and it is in a state ready for installation and use. Consequently, According to Rule 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 7020.0099.

 

Ruling No.	J2025-0004	HS code	7308.3000
Commodity Name	Glass Shower Enclosure with a Stainless Steel Frame	Specifications	In bulk, each piece is 10 - 40 centimeters in length
Product Description	This product comprises two fixed flat panels of tempered glass, two sliding curved panels of tempered glass, a stainless steel frame incorporating curved track channels, rollers, hinges, door handles, and related hardware. It is supplied without a shower base (tray), top cover, or any shower fixtures. Upon assembly, it forms a fully framed, curved glass shower enclosure with sliding doors, designed for installation against an L-shaped (two-walled) corner.
Classification Ruling	The essential character of this product, composed mainly of a stainless steel frame and tempered glass, is imparted by its metal frame. This places it within the scope of door and window frames, classified as "structures and parts of structures, of iron or steel" under Heading 73.08. Consequently, According to Rule 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 7308.3000.

 

A glass shower enclosure is typically constructed from tempered glass, a metal frame, and associated hardware. It is a key fixture in modern bathrooms, designed to create a separate, contained shower area. The tempered glass, whether transparent or translucent, separates the shower area while preserving a sense of visual openness for the bathroom. It effectively keeps water within the shower, thereby enhancing convenience and allowing for more efficient use of space. As composite articles made up of different materials or components, they are classified based on the elements that determines their essential character.

1. Pursuant to classification ruling for “Glass Shower Enclosure” (Ruling No. J2025-0003), this product consists of glass walls and door panels, an aluminum frame (on the wall-mounting side only), a top rail, hinges, door handles, and related hardware. These components together form a glass partition which, together with the bathroom walls, encloses a shower space. The essential character of the product is therefore determined by its glass walls and door panels. It consequently falls to be classified as an article of glass. According to Rule 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under Heading 70.20, with the specific HS code 7020.0099.

2. Pursuant to classification ruling for "Glass Shower Enclosure with Stainless Steel Frame" (Ruling No. J2025-0004), this product comprises a fully framed structure consisting of a stainless steel border frame and curved track channels, along with tempered glass panels, forming a glass partition in conjunction with the bathroom walls. The essential character of the product is therefore determined by its fully framed (metal) structure. It consequently falls to be classified as a structure of stainless steel. According to Rule 3(b) and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under Heading 73.08, with the specific HS code 7308.3000.

XIII. Van

 

Ruling No.	J-2025-0005	HS code	8703.2413
Commodity Name	Van	Specifications	Toyota, 3456 cc
Product Description	Vehicle Model: HIACE A3.5L. Engine type: petrol; Displacement: 3,456 cc; Drive type: rear-wheel drive; Rated seating capacity: 2 persons. The vehicle is fitted with a side sliding door that has window openings but no glazing. At the rear, it has a top-hinged tailgate which incorporates a window. The rear cargo area is spacious and features a floor with pre-drilled holes for seat mounting. It is not separated from the driver and front passenger area by any fixed partition or barrier.
Classification Ruling	The vehicle is a van (multi-purpose vehicle). As presented, it is fitted with a petrol engine having a displacement of 3,456 cc. It lacks a fixed partition or barrier of requisite strength between the driver/front passenger area and the rear cargo area. Its configuration includes a side sliding door (with window openings) and a top-hinged rear tailgate with a window. Taken together, these characteristics establish that the commodity constitutes a semi-finished passenger vehicle. Consequently, according to Rule 2(a) and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 8703.2413.

 

Ruling No.	J-2025-0006	HS code	8703.3213
Commodity Name	Van	Specifications	Mercedes-Benz Sprinter, 1,950 cc
Product Description	Vehicle Model: Sprinter D2.0S. Engine type: diesel; Displacement: 1,950 cc; Drive type: rear-wheel drive; Seating capacity: 2 persons. The vehicle is fitted with a side sliding door that has window openings but no glazing. At the rear, it has barn doors which incorporate windows. It lacks a fixed partition or barrier between the driver/front passenger area and the rear cargo area.
Classification Ruling	The vehicle is a van (multi-purpose vehicle). As presented, it is fitted with a diesel engine having a displacement of 1,950 cc. It lacks a fixed partition or barrier of requisite strength between the driver/front passenger area and the rear cargo area. Its configuration includes a side sliding door (with window openings) and rear barn doors with windows. Taken together, these characteristics establish that the commodity constitutes a semi-finished passenger vehicle. Consequently, according to Rule 2(a) and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 8703.3213.

 

The vehicles subject to these two rulings share a key defining characteristic: a single, undivided enclosed interior space with a seating capacity of two in the front. Under prevailing industry standards, a van configured for cargo transport must be fitted with a fixed, solid partition of sufficient strength between the driver/passenger area and the cargo area. The vehicles herein, as presented for Customs clearance, are notably lacking this essential feature. Furthermore, the vehicles are configured with side sliding doors and exhibit prepared mounting points for both seats and window glass. The rear compartment is fitted with windows, and they are declared for import to be subsequently converted into passenger vehicles. Taken together, these characteristics establish that the commodities are incomplete passenger vehicles. According to Rule 2(a) of the General Rules for the Interpretation of the Harmonized System, they are classified as complete passenger vehicles under Heading 87.03.

XIV. Decommissioned Aircraft, Dismantled for Display

 

Ruling No.	J-2025-0007	HS code	8807.3000
Commodity Name	Decommissioned Aircraft, Dismantled for Display	Specifications	Boeing Airframe (stripped)
Product Description	This product is a decommissioned aircraft, dismantled for static display or similar purposes. It consists of an airframe shell that has been stripped of its internal installations, including instruments, avionics, seats, overhead bins, and interior furnishings (sidewall panels, air conditioning, emergency oxygen systems, lighting, lavatories, and galleys). It retains one engine (in a non-operational state), an Auxiliary Power Unit (APU), landing gear, and brake discs. In this configuration, the aircraft is incapable of flight. Its potential applications range from use as a training aid or static display to conversion into an aviation-themed venue. Alternatively, the airframe can be dismantled for material recovery and recycling.
Classification Ruling	Given its suitability for multiple purposes, the aircraft does not meet the exclusive criteria for Heading 90.23 as set out in the Explanatory Notes: "This heading covers a wide range of instruments, apparatus and models designed for demonstrational purposes (e.g., in schools, lecture rooms, exhibitions) and unsuitable for other uses". Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 8807.3000.

 

This commodity is a decommissioned aircraft, dismantled for display. It consists of an airframe shell rendered incapable of flight by the removal of internal components. Key removals include instruments, avionics, seats, overhead bins, and interior furnishings (sidewall panels, air conditioning, emergency oxygen systems, lighting, lavatories, and galleys). It retains one non-operational engine, an Auxiliary Power Unit (APU), landing gear, and brake discs. In practice, these airframes are used for diverse purposes, such as serving as university training aids, conversion into aviation-themed restaurants, or being dismantled for aluminum recycling.

As noted in the Explanatory Notes to Heading 90.23, that heading is strictly for "a wide range of instruments, apparatus and models designed for demonstrational purposes (e.g., exhibitions) and unsuitable for other uses". Given multiple uses of this aircraft, it does not meet this exclusive criterion on “designed for demonstrational purposes (e.g., in schools, lecture rooms, exhibitions) and unsuitable for other uses". Therefore, it is properly classified as aircraft parts under Heading 88.07 of the Tariff. Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 8807.3000.

XV. Covidien Endo GIA Ultra Universal Stapler 

 

Ruling No.	J-2025-0007	HS code	8807.3000
Commodity Name	XV. Covidien Endo GIA Ultra Universal Stapler	Specifications	Covidien
Product Description	This product, the Covidien Endo GIA Ultra Universal Stapler, is an endoscopic/laparoscopic linear cutter stapler. Electromechanically powered, the stapler is designed to ligate, transect, and anastomose blood vessels and tissues in surgery. It features the following primary components: a pin, shaft, articulating head knob, rotating collar, green firing button, black return button, light blue cartridge release button, and a pistol-grip handle. In laparoscopic procedures, the stapler must be used in conjunction with an endoscope. In open surgery, its use is straightforward, with the surgeon manipulating it by hand within the open wound.
Classification Ruling	This product is an electromechanically powered surgical instrument. Although primarily designed for use with an endoscope to transect tissues and create anastomoses inside the body during laparoscopic procedures, when presented separately for Customs clearance, it constitutes a surgical stapling device. As such, it meets the description of "surgical staplers for implanting staples to suture wounds" under Heading 90.18 of the Explanatory Notes. Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 9018.9099.

 

Covidien Endo GIA Ultra Universal Stapler, an endoscopic/laparoscopic linear cutter stapler, is an electromechanically powered surgical stapling device comprising multiple functional components. Its core function is to ligate, transect, and anastomose blood vessels and tissues within the body during surgery.

The device is intended for use in both laparoscopic and open surgery. In laparoscopic procedures, it must be used in conjunction with an endoscope to perform internal anastomosis under video-guided visualization. In open surgery, the surgeon can handle it directly under vision within the surgical wound, eliminating the need for an endoscope.

The instrument may be used either in conjunction with an endoscope or independently. In either case, it is itself a medical device with stapling capability. Moreover, the device satisfies the definition of "surgical staplers for implanting staples to suture wounds" as set forth in the Explanatory Notes to Heading 90.18. Therefore, it is properly classified as a medical device under Heading 90.18. Being an electromechanically powered surgical stapler, it finds no more specific listing within the subheadings of Heading 90.18. Consequently, according to Rule 1 and 6 of the General Rules for the Interpretation of the Harmonized System, it is classified under HS code 9018.9099.

Prepared by: Department of Duty Collection of the General Administration of Customs, General Administration of Customs Tax Collection and Administration Bureau (Beijing, Tianjin, Shanghai, and Guangzhou).

 

 

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