HS Chapter 90 Duty Rate of 15 Percent Under Cabinet Decision 393

1. Key takeaways

Under the tariff reduction table issued pursuant to Cabinet Decision No. 393, HS Chapter 90 (Class XVIII: instruments and appliances for optics, photography, cinematography, measurement, checking, supervision or precision control; medical or surgical instruments and appliances; and their parts and accessories) applies a rate of 15%, with a unit of measurement of items. The adjacent chapter-level rates given by the same table are: medicines (HS 30) 10%; medical and surgical furniture (HS 94) 15%; dental waxes and gypsum-based dental preparations (HS 34) 10%; machinery and electrical equipment (HS 84/85) 30%; pearls and precious metals (HS 71) 0.5%. For the same medical use, the difference between Chapter 30 and Chapter 90 is 5 percentage points, and between Chapter 90 and Chapter 85 it is 15 percentage points. This is a chapter and item level rate table, not an 8-digit subheading level table; the applicable rate of a specific tariff line must be determined by classification into a chapter under the HS rules. The table carries only one rate column and does not list the pre-reduction rate, so any statement of a fall from X% to 15% is an inference, not the text. GRZAN’s usage rule follows: use 15% for order-of-magnitude judgement and use the classification conclusion as the quotation basis.

• Chapter 90 (medical and surgical instruments among others) carries 15%; unit of measurement is items.
• Chapter 30 medicines carry 10%, 5 points below Chapter 90; machinery and electrical equipment carry 30%, 15 points above.
• The table is chapter and item level only; specific tariff lines depend on HS classification.
• One rate column only — no pre-reduction rate, so reduction claims cannot be supported by the text.

Scope of this article. The classification basis and the Customs Tariff Law No. 22 (2010) framework are covered in article 30; this article models the duty burden structure and its funding impact only.

2. Legal basis

The instruments below carry the rate and its legal source.

Extracts of the operative provisions. The item description of row 90 of the tariff reduction table covers instruments and appliances for optics, photography, cinematography, measurement, checking and supervision or precision control, medical and surgical instruments and appliances, and their parts and accessories; the rate column reads 15% and the unit of measurement is items. Article 1 of the Customs Tariff Law No. 22 (2010) levies import duties on imported goods according to the customs tariff schedule annexed to the law and the agricultural calendar — the legal source of the rates. Article 2 provides that the Council of Ministers may, at the request of the Federal Finance Minister and where urgent economic or monetary needs arise, revise the whole or part of the tariff schedule — the legal channel of the Cabinet Decision 393 reduction table.

Chapter-level rate comparison (from the tariff reduction table; chapter and item level, not subheading level).

The table also carries: Chapters 25–27 (mineral products) 15%; Chapters 28–33 (including medicines) 10%; Chapters 44–63 (wood, paper, textiles) 15%.

3. Expert insights

A chapter-level rate supports an order-of-magnitude judgement, not a quotation. Chapter 90 spans diagnostic equipment, therapeutic equipment, surgical instruments, orthopaedic appliances and radiation devices, and a single 15% covers all of them. A quotation model that multiplies 15% by cargo value carries error from chapter classification and customs value determination. The classification difference is real money: a device containing pharmaceuticals classified into Chapter 30 rather than Chapter 90 differs by 5 percentage points; goods classified as electrical equipment into Chapter 85 differ by 15 percentage points. Under the HS General Rules a specific description prevails over a general one, so dedicated medical equipment normally stays in Chapter 90; goods that genuinely fall into 30% are those without a dedicated medical listing declared as general machinery or electrical equipment — a classification judgement, not a provision of this table. GRZAN’s practice is to place 15% in the cost model as the midpoint of a duty range, never as a fixed value.

Debunking the claim that the Iraqi duty on medical devices was reduced from X% to 15%. The table has a single rate column and does not list the pre-reduction rate; the listed rates are the rates after reduction. The reduction figures circulating online have no source in the text. Likewise, describing 15% as a unified medical device rate fails: the rate belongs to the single chapter 90 and is not set by the regulatory concept of a medical device.

The difference between chapter level and subheading level is the difference in classification dispute risk. The Chinese import and export tariff schedule and the EU TARIC publish rates at 8-digit and 10-digit subheading level year by year, many with annual provisional rates, so quotations can reach subheading precision in advance. Iraq’s single table gives chapter-level single-line rates; the consequence is not a higher rate but more room for classification disputes and less predictable outcomes: the same product may have two or three plausible placements while the official text gives no subheading-level answer.

4. Practical recommendations

• GRZAN performs HS pre-classification at the quotation stage, with the manufacturer’s regulatory department and the GRZAN regulatory team responsible and the quotation date as the timing point; the pre-classification conclusion is written into the cost model in written form and marked as a classification opinion, not an official advance ruling.
• Issue duty estimates as a range, annotated as follows: based on the chapter-level rates of the tariff reduction table pursuant to Cabinet Decision No. 393; the rate of the specific tariff line follows the customs classification conclusion.
• Keep the units of measurement on commercial invoices and packing lists consistent with the items unit of row 90, reducing verification round trips in ASYCUDA declaration — the prepayment estimate is computed from customs classification, goods type, origin and value (see article 36). Practical estimate: checks caused by unit mismatch usually add 3–5 working days (no official provision found).
• Before each import batch, re-check on the Ministry of Finance website whether the table has been updated; the Council of Ministers may revise the whole or part of the tariff schedule at the Finance Minister’s request, so rates should not be locked into long-term contracts.

5. Verification checklist

• □ Re-download the Ministry of Finance table and check row 90: rate 15%, unit of measurement items.
• □ Check whether the table carries a parallel pre-reduction rate column; if not, the constraint of never writing a fall from X% to Y% remains in force.
• □ Perform the chapter placement for the specific product under the HS General Rules and record the classification reasoning and the item wording.
• □ Re-check Articles 1, 2 and 11 of the Customs Tariff Law No. 22 (2010) and confirm the wording on the legal source of the rates and the revision mechanism.
• □ Search for the original of Cabinet Decision No. 393 to complete primary evidence of its number and publication date.
• □ Re-check whether the official documents cited here have been replaced by later instructions or decisions (verification baseline date: 29 October 2026).

Regulatory information verified as of 29 October 2026.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Iraqi market. Our team coordinates local importer arrangements, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com