Ms. Patricia Choo
ITOCHU International Inc.
335 Madison Avenue
New York, NY 10017

RE: The tariff classification of Rodent Repellent Polyvinyl Chloride Adhesive Tape from Japan

Dear Ms. Choo:

In your letter dated September 24, 2013, you requested a tariff classification ruling. You provided a sample, which will be returned to you.

The subject product is described as an adhesive tape composed of polyvinyl chloride, a rubber based adhesive and capsaicin (red pepper) extract. According to your letter, the polyvinyl chloride film is 0.16mm and the rubber based adhesive is 0.04mm thick. The tape is indicated for use as a rodent deterrent when wrapped around wires, pipes etc.

The applicable subheading for the Rodent Repellent Polyvinyl Chloride Adhesive Tape will be 3808.91.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Insecticides, … , put up in forms or packings for retail sale or as preparations or articles (for example, sulfur-treated bands, wicks and candles, and flypapers): Insecticides: Other: Other: Other." The rate of duty will be 5 percent ad valorem.

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

This merchandise may be subject to the requirements of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), which is administered by the U.S. Environmental Protection Agency (EPA), Office of Pesticide Programs. Information on the FIFRA can be obtained by calling the EPA at (202) 260-2090, or by visiting their website at

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 Paul Hodgkiss at (646) 733-3046.


Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division