Ms. Brenda L. Thompson
UniTao Pharmaceuticals LLC
2820 N Normandy Drive
Petersburg, VA 23805

RE: The tariff classification of Citrulline, Citrulline Malate 1:1and Citrulline Malate 2:1, from China

Dear Ms. Thompson:

In your letter dated December 08, 2015, you requested a tariff classification ruling.

The subject products which you are requesting classification on are:

1) Citrulline (CAS # 372-75-8), 2) Citrulline Malate (1:1), and; 3) Citrulline Malate (2:1).

All three products are from China. You indicate that the CAS # for Citrulline is 372-75-8. The material will be sold to customers for use in the manufacturing of nutraceutical products. The Citrulline chemical structure possesses both intact Amide and Amino functional groups. For purposes of this ruling, we assume that the Citrulline product is pure, and is a separately identified organic chemical compound with no additional ingredients.

The applicable subheading for the Citrulline (CAS # 372-75-8) will be 2924.19.1150, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: "Carboxy-amide-function compounds; amide-function compounds of carbonic acid: Acyclic amides (including acyclic carbamates) and their derivatives; salts thereof: Other: Amides: Other.". The duty rate will be 3.7 Percent.

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

Your inquiry does not provide enough information for us to give a classification ruling on the Citrulline Malate (1:1), and Citrulline Malate (2:1). Your request for a classification ruling should include a complete chemical breakdown with the percentage of each component present in the product.

Also provide a detailed explanation of how the items are used, and what the purpose of the non-Citrulline component is in the finished product.

When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 above, contact National Import Specialist Paul Hodgkiss at (646) 733-3046 or via email at Paul.Hodgkiss@CBP.DHS.Gov.


Gwenn Klein Kirschner
National Commodity Specialist Division