Diagnostic Imaging Equipment Imports

Diagnostic imaging equipment – MRI, CT, ultrasound, X-ray – classifies under HTS 9018 or 9022 depending on imaging modality. FDA Class I/II/III medical device classification. Section 232 MedTech investigation could affect this category. Most equipment manufactured by GE Healthcare, Siemens Healthineers, Philips, Canon Medical.

This guide covers U.S. import tariff and compliance for diagnostic imaging equipment.

For SMB importers in this category, the practical questions are HTS classification, applicable Section 232/301/122 stacks, FTA opportunities, and regulatory overlay (FDA/USDA/EPA/CPSC where relevant).

HTS classification basics

X-ray equipment HTS 9022.14. CT scanners HTS 9022.12. MRI HTS 9018.13 (medical electrodiagnostic apparatus). Ultrasound HTS 9018.12.

Tariff stack and rates

Base 0% (most medical imaging equipment is duty-free under MFN) + Section 122 (15% on non-USMCA) + potential Section 232 MedTech (TBD).

Country of origin considerations

GE Healthcare (U.S.), Siemens Healthineers (Germany), Philips (Netherlands), Canon Medical (Japan). Limited China dependence for high-end equipment.

Regulatory overlay

FDA Class II/III medical device. 510(k) or PMA pathway. Specific FDA radiation safety standards. Foreign establishment registration.

Mitigation opportunities

EU and Japanese origin avoid Section 301. USMCA qualification limited (most production outside North America).

Frequently asked questions

What is the typical effective duty rate?

Depends on origin and HTS classification. China-origin: 22-42% effective when Section 301 + Section 122 stack. USMCA-qualifying Mexican production: often 0-3%. Vietnam, India, Korea: 15-17% with Section 122.

Can I qualify under USMCA?

Possible if production occurs in U.S., Mexico, or Canada and meets rules of origin (typically 60% RVC under transaction value or 50% net cost). USMCA-qualifying goods are exempt from Section 122.

Are IEEPA refunds available?

Yes – for entries between April 5, 2025 and February 24, 2026 that paid IEEPA duty. Filed through CBP’s CAPE portal. We file claims on contingency for filings above $50k.

What about Section 232 exposure?

Specific to product type. Steel and aluminum derivatives expansion brought some downstream products into scope. Component-level analysis identifies actual coverage.

How do you help with this category?

Tariff exposure assessment ($2,500-$7,500), classification audit, USMCA qualification, refund recovery, audit response. Independent of any customs brokerage.