Ms. Lizbeth R. Levinson
Kutak Rock LLP
Suite 1000
1101 Connecticut Ave., N.W.
Washington, D.C. 20036-4374

RE: The tariff classification of beef sticks from Brazil.

Dear Ms. Levinson:

In your letters dated December 30, 2009 and April 5, 2010, you requested a tariff classification ruling on behalf of Links Snacks, Inc. (Glarus, WI).

The goods in question (item # 89204) are “beef sticks,” which are said to be beef sausages having collagen casings. In photos accompanying your most recent letter, the beef sticks appear to resemble frankfurters. The ingredients are beef, salt, spices, dextrose, sugar, corn syrup, monosodium glutamate, water, sodium erythorbate, lactic acid starter culture, flavoring, sodium nitrite, BHA, BHT and citric acid. The beef is treated with a solution of potassium sorbate to ensure freshness.

The beef sticks are said to be manufactured as follows: the meat is ground, combined with water and other ingredients, and mixed to a uniform consistency. The mixture is stuffed into collagen casings. The stuffed sausages are placed on metal rods for fermentation, cooking and drying. They are then packed in sealed plastic bags with an added oxygen scavenger. The sealed bags are said to be airtight.

The applicable subheading for the above-described beef sticks will be 1601.00.4090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for sausages and similar products, of meat, meat offal or blood; food preparations based on these products: other: beef in airtight containers: other. The rate of duty will be 3.4%.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at

Articles classifiable under subheading 1601.00.4090, HTSUS, which are products of Brazil, may be entitled to duty-free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at and search for the term “GSP”.

The importation of the merchandise discussed in this ruling is subject to requirements administered by the following U.S. Department of Agriculture agencies, which may be contacted for further information:

USDA FSIS Technical Service Center Suite 300, Landmark Center 1299 Farnam Street Omaha, NE 68102 Tel. (402) 344-5000 Website:

USDA APHIS, VS National Center for Import and Export 4700 River Road, Unit 40 Riverdale, MD 20737 Tel. (301) 734-3277 Website:

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Nathan Rosenstein at (646) 733-3030.


Robert B. Swierupski
National Commodity Specialist Division