Tariff and customs classification
Tariff and customs classification for Healthcare & Life Sciences products is one of the more technically unforgiving compliance areas in international trade, where a single Harmonized System code misapplication on medical devices or pharmaceutical inputs can trigger duties, seizures, or import holds. The U.S. Customs and Border Protection and the U.S. Food and Drug Administration share overlapping jurisdiction at the border, and in Europe, national customs authorities operating under European Union Combined Nomenclature rules have tightened scrutiny on combination products and IVD reagents since the EU Medical Device Regulation fully took effect. Classification disputes are not theoretical: binding ruling requests, prior disclosure filings, and CBP audit activity have all increased in the post-tariff-action environment covering Chinese-origin components.
Watch
- CBP's HTSUS Chapter 98 provisions as applied to returned U.S.-origin medical goods
- EU Combined Nomenclature 2024 updates affecting IVD reagent classification under Chapter 38 versus 30
- Section 301 List 4A tariff exposure for Chinese-origin pharmaceutical APIs and device subcomponents
- FDA-CBP data-sharing on misclassified combination products flagged at port of entry
- Japan Customs tariff classification guidance on single-use surgical robots under HS 9018
Recent material activity in Healthcare & Life Sciences
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FDA issues Complete Response Letter for novel GLP-1 receptor agonist oral formulation
The FDA issued a CRL for a once-daily oral GLP-1 receptor agonist citing manufacturing consistency concerns at the primary production facility. The agency requested additional CMC data and a pre-approval inspection befor…
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