That HRL does, in fact, concern the applicability of HTSUS 9817.00.92-.96 to certain items.
Although you do not propose the applicability of a secondary classification under HTSUS 9817.00.92-.96 (which provides for articles specially designed or adapted for the benefit of the blind or handicapped), you did attach a page with what appears to be a paragraph from an unspecified CBP ruling which discusses Headquarters Ruling Letter (HRL) 556449, dated May 5, 1992. The frequency variations resulting from the time taken for the ultrasonic beam to travel out to an obstacle and be reflected back enable the user, through an appropriate device (e.g., an internal ear piece), to detect the obstacle and judge its distance.” The applicable subheading for the iGlasses will be 90, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "other" Appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability and parts and accessories thereof. These consist essentially of an ultrasonic transmitter receiver powered by an electric battery. It is thus very similar to the items described in Harmonized System Explanatory Note V-3 to 9021, i.e., Per the AmbuTech flyer you provided, the iGlasses is an Ultrasonic Mobility Aid which “detects objects in your path – gentle vibrations increase as you get closer.” It is clearly intended for those who are either totally blind or have vision so poor that it cannot be improved sufficiently even to see objects in their path by optical or opto-electronic means. Crotty: In your letter dated February 17, 2011, on behalf of Ambutech, Inc., you requested a tariff classification ruling. RE: The tariff classification of iGlasses from China.
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