Chapter 90 covers optical, photographic, cinematographic, measuring, checking, medical or surgical instruments and apparatus, precision instruments and apparatus, and parts and accessories thereof. This chapter is one of the most technologically advanced chapters in the HS system, involving various precision instruments from eyeglasses and microscopes to CT machines and cardiac pacemakers. Its core characteristic is that the goods possess professional functions such as measurement, detection, treatment, and surgery, and typically have high added value. This chapter also includes medical sterilization equipment, mechanotherapy appliances, massage appliances, etc., but excludes ordinary mechanical or electrical equipment (classified in Chapter 84 or 85). Heading 9018 covers instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments. Specifically includes: electrocardiographs, ultrasonic diagnostic apparatus, nuclear magnetic resonance imaging equipment, CT scanners, ventilators, anesthesia machines, dialysis machines, extracorporeal circulation equipment, etc. This heading includes both electrical medical equipment and non-electrical surgical instruments. However, it excludes: orthopedic appliances (9019), prosthetics (9021), dental chairs (9402), and ordinary medical furniture. Code 901835 is a 6-digit subheading: the first 2 digits '90' represent Chapter 90 (optical, medical and other precision instruments); digits 3-4 '18' represent heading 9018 (instruments and appliances used in medical, surgical, dental or veterinary sciences); digits 5-6 '35' represent subheading 9018.35, specifically 'Extracorporeal membrane oxygenation (ECMO) machines'. In HS classification, ECMO, as a life support device that achieves blood oxygenation and carbon dioxide removal through extracorporeal circulation, is explicitly listed under 9018.35. This subheading was newly added in the 2022 version of the HS to reflect the importance of ECMO in critical care. It is not further subdivided, but individual countries may extend to 8-10 digit codes based on function (e.g., whether it includes a pump, whether monitoring is integrated). Extracorporeal membrane oxygenation (ECMO) machines are classified under 9018.35 rather than other codes for the following reasons: 1) ECMO is a life support device used directly for human treatment, meeting the definition of 'medical instruments' under 9018; 2) its core function is extracorporeal circulation and oxygenation, belonging to cardiovascular treatment equipment, rather than ordinary pumps or ventilators (breathing appliances under 9019 do not include extracorporeal circulation); 3) ECMO is not classified under 8481 (valves) or 8413 (pumps) because as a complete medical system, its function exceeds that of a single component. Therefore, 9018.35 is a subheading specifically established for ECMO to ensure precise classification.

Product Name (Chinese and English): The standard name of the declared commodity, which should be consistent with the HS code description. In Chinese, it is '体外膜肺氧合机', and in English, it is 'Extracorporeal Membrane Oxygenation Machine', which can be abbreviated as ECMO. Brand (Chinese and foreign language): Fill in the registered trademark of the manufacturer, such as '迈柯唯 MAQUET', '索林 Sorin', etc. If there is no brand, fill in 'none'. Model: Fill in the specific model of the equipment, such as 'Rotaflow', 'CARDIOHELP', etc., to distinguish different specifications under the same brand. Purpose: Briefly describe the purpose of the equipment, such as 'used for extracorporeal life support in patients with cardiopulmonary failure', which needs to reflect the medical treatment purpose. Working Principle: Explain how the equipment achieves oxygenation, such as 'driving blood through the membrane lung via a centrifugal pump for gas exchange', highlighting the core mechanism. Whether it includes a pump: Clearly state whether the equipment includes a blood pump (such as a centrifugal pump or roller pump). ECMO with a pump is usually classified under 9018.35, while ECMO without a pump may be classified under other subheadings. Components: List the main components, such as 'main unit, centrifugal pump, membrane lung, tubing, monitoring system', to facilitate customs determination of whether it is a complete device. Packaging Specifications: Fill in the packaging method and quantity, such as '1 unit/wooden crate', affecting inspection and statistics. Example of customs declaration elements: Product Name: Extracorporeal Membrane Oxygenation Machine (ECMO) Brand: 迈柯唯 MAQUET Model: Rotaflow Purpose: Used for extracorporeal life support in patients with cardiopulmonary failure Working Principle: Drives blood through the membrane lung via a centrifugal pump for gas exchange Whether it includes a pump: Includes centrifugal pump Components: Main unit, centrifugal pump, membrane lung, tubing, monitoring system Packaging Specifications: 1 unit/wooden crate HS Code: 90183500 Mistakenly classifying ECMO under 9019 (breathing appliances), but ECMO is extracorporeal circulation equipment and does not directly provide respiratory support. Ignoring the 'whether it includes a pump' element; ECMO without a pump may be classified under 9018.90 or other subheadings. Declaring ECMO parts (such as membrane lung) separately as 9018.35, but parts should be classified under 9018.90 or specific part codes.

Core criteria for classification: 1) Whether the product's function is extracorporeal membrane oxygenation, i.e., achieving blood oxygenation and carbon dioxide removal through extracorporeal circulation; 2) whether it constitutes a complete medical device rather than parts or accessories; 3) whether it is used for human treatment rather than experimental or animal use; 4) whether it has core components such as a pump and membrane lung. If the above conditions are met, it is classified under 9018.35. If it is only a membrane lung or pump, it is classified as parts (9018.90). If it is ECMO for animals, it is still classified under 9018.35 because the heading covers veterinary instruments. 901890 Other medical instruments and appliances: 9018.90 is a residual subheading covering medical devices not elsewhere specified. ECMO has a dedicated subheading 9018.35, so it is not classified under 9018.90. However, if ECMO parts are declared separately, they may be classified under 9018.90. 901920 Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus: 9019.20 includes ventilators, oxygen masks, etc., but ECMO is extracorporeal circulation equipment and does not directly provide respiratory gas, so it is classified under 9018.35. 841370 Other centrifugal pumps: 8413.70 is for general-purpose pumps, while ECMO is an integrated medical system, and its pump is a dedicated component; the complete machine is classified under 9018.35. If a centrifugal pump is imported separately, it may be classified under 8413.70. 902214 X-ray equipment for medical, surgical or veterinary use: 9022 is for X-ray equipment, which is completely different in function from ECMO, but both are medical equipment and are easily confused due to the word 'medical'. 901819 Other electro-diagnostic apparatus: 9018.19 includes diagnostic equipment such as electrocardiographs and electroencephalographs, while ECMO is therapeutic equipment, so it is classified under 9018.35. Is the device used for extracorporeal membrane oxygenation? Does it include a blood pump and membrane lung? Is it used for human or animal treatment? Is it imported as a complete device? Is it confused with a ventilator or dialysis machine?

The HS code 901835 for ECMO only appeared in the 2022 version of the HS. How was it classified before? Before the 2022 version, ECMO had no dedicated subheading and was usually classified under 9018.90 (other medical instruments) or 9018.19 (other electro-medical apparatus). The 2022 version of the HS added subheading 9018.35 to reflect the importance of ECMO in critical care, making its classification more precise. Enterprises using old codes need to update. When importing ECMO, how does the declaration element 'whether it includes a pump' affect classification? Subheading 9018.35 is explicitly for 'extracorporeal membrane oxygenation machines', usually referring to complete ECMO systems with a pump. If the imported ECMO does not include a pump (e.g., only membrane lung and tubing), it may be classified under 9018.90 or other subheadings. Therefore, it is essential to specify whether a pump is included during declaration to avoid classification disputes. If the membrane lung of ECMO is imported separately, which code should it be classified under? As a dedicated part of ECMO, if the membrane lung is imported separately, it should not be classified under 9018.35 (complete machine) but as a part. It is usually classified under 9018.90 (parts of other medical instruments), but it is necessary to confirm whether it constitutes a part of another subheading. It is recommended to provide detailed technical information for customs advance classification. How to distinguish ECMO from hemodialysis machines (9018.49)? ECMO is mainly used for extracorporeal life support in cardiopulmonary failure, with the core being oxygenation and circulation; hemodialysis machines (9018.49) are used for renal failure, removing metabolic waste through a semipermeable membrane. They have different functions and different HS codes. ECMO is classified under 9018.35, and dialysis machines under 9018.49. How to check the tariff rate for ECMO? Tariff rates depend on the importing country, country of origin, trade agreements, etc. Enterprises can check the corresponding tariff rate for the HS code on the importing country's customs website, or use China Customs' 'Import and Export Tariff'. Note that rates may change, and it is recommended to use the latest version. In addition, ECMO may enjoy tax exemption policies for medical equipment, which need to be verified. Does ECMO require an export license when exporting? ECMO is high-tech medical equipment, and some countries may impose export controls. Enterprises need to check their country's export control list, such as China's 'Catalogue of Dual-Use Items and Technologies Subject to Import and Export License Administration'. If ECMO is listed, a license is required. General civilian ECMO may not be controlled, but it is advisable to consult customs or commerce departments. Is the HS code for ECMO consistent across countries? The first 6 digits of the HS code are unified internationally, but countries may extend to 8-10 digits. For example, China Customs may use 90183500, and the US HTSUS is 9018.35.00. Enterprises need to fill in the complete code according to the importing country's requirements. The first 6 digits are consistent, but the latter digits may differ, so it is necessary to check the target country's tariff schedule. How to determine whether it is a part or a complete ECMO machine? A complete machine refers to equipment that has complete ECMO functions and can be used independently; a part refers to a component that cannot independently perform ECMO functions, such as a membrane lung, pump head, tubing, etc. If core components (such as pump or membrane lung) are missing at the time of import, it may be regarded as a part. It is recommended to provide product manuals and functional descriptions, subject to customs determination.