Mr. Michael Howe
NPD Products Ltd
2325 Old Second South
Midhurst, ON L0L 1X0

RE: The tariff classification of the Bed Bug ALERT™ Monitor from China

Dear Mr. Howe:

In your letter, received by this office on July 14, 2014, you requested a tariff classification ruling. An unmarked representative sample was submitted with your request and will be returned to you.

The product to be imported is the Bed Bug ALERT™ Monitor in bulk 12-packs. This item is comprised of a clear plastic housing measuring approximately 2”x 3” containing a scented proprietary gel and adhesive coated paper board that both attracts and traps. This monitoring device can be used in homes, hotels, cars, luggage, or in any other places that bed bugs may be suspected.

The applicable subheading for the Bed Bug ALERT™ Monitor will be 3808.91.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insecticides, rodenticides, fungicides, herbicides, antisprouting products and plant-growth regulators, disinfectants, and similar products, put up in forms or packings for retail sale or as preparations of articles (for example, sulfur-treated bands, wicks and candles, and flypapers): Other: Insecticides: 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

You indicate that in the future the Bed Bug ALERT™ Monitor bulk units may be broken down and repackaged in the United States. Please note that in such instances the certification procedures set forth in 19 CFR 134.25/134.26 should be followed to ensure that ultimate purchasers are aware that the country of origin of the repacked goods is China.

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. For further guidance, you should contact the U.S. Environmental Protection Agency (EPA), Office of Pesticide Programs, at 1200 Pennsylvania Avenue, NW (Mail code 7501P), Washington DC, 20460 by calling 703-305-7090 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 Judy Lee at judy.h.lee


Gwenn Klein Kirschner
National Commodity Specialist Division