This is an HS Classification case study. We will look at how the HS code for a cytology brush is determined. This product is manufactured in the United States of America. This product can be used to collect cells from the lower respiratory tracts of patients. For reference, the product is similar to products that can be found in this link. In our case study, we will assume that the bristles of the brush are made of nylon and that the main stem of the brush is made of stainless steel. We will also assume that the country of import is Singapore.

This product may be considered a medical device in some countries and require special registrations prior to import.

Potential HS Chapters to narrow down where the possible Headings may be found in

Looking through the possible Chapters in the nomenclature, we can narrow down the options to:

  1. Chapter 90: Medical instruments
  2. Chapter 96: Miscellaneous manufactured articles
  3. Chapter 73: Articles of iron or steel

Apply General Rules of Interpretation to get the HS code for the brush

Applying WCO’s rules of classification we will attempt to first use GRI 1. By searching the tariff text, we can see that brushes appear in Headings 9603. Although the term “brush” does appear in other Headings, by looking at the description in the Headings we can very clearly see that the rest are referring to other kinds of brushes such as carbon brushes and artists brushes.

Check the Section & Heading Notes

Now reading the Heading notes for Heading 9603, we can very clearly see that medical use brushes are EXCLUDED from this Chapter. In fact, the notes point us to classify them under Heading 9018. We now know that the Heading for brushes is likely to be 9018. However, we have to inspect the Section, Chapter, and Heading Notes to be sure. After reading through them we can conclude that 9018 is the right place to be looking at.

Determine the Sub-Headings and complete HS code classification for the brush

As we review the sub-headings for heading 9018, we have to choose between several options such as syringes, ultrasonic scanning equipment, MRI machines, dental instruments, etc. We can conclude that the description in sub-heading 9018.90 is most suitable for the cytology brush. The description for this chapter is for other instruments that could not be described in the descriptions that appeared before it. At this point, we can assign the final HS code for this material pretty easily – 90189090.

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