Mr. Rick Van Arnam
Barnes, Richardson & Colburn LLP
100 William Street, Suite 305
New York, NY 10038

RE: The tariff classification of Bio-Cellulose Powder from Vietnam

Dear Mr. Van Arnam:

In your letter dated May 25, 2018 you requested a tariff classification ruling for Bio-Cellulose Powder on behalf of your client, JBH Intertrade LLC. A representative sample was submitted with your request and will be retained by this office.

Bio-Cellulose Powder, also known as bacteria cellulose, is produced via a fermentation process. The form of this product, at the time of importation, is an ultrafine powder. You state that the bio-cellulose powder has the same molecular formula and chemical structure as plant-derived cellulose. The powder will be sold for use by food and beverage companies to increase the per serving fiber content of products.

The applicable subheading for the Bio-Cellulose Powder will be 3912.90.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Cellulose and its chemical derivatives, not elsewhere specified or included in primary forms: Other: Other. The general rate of duty will be 5.2 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 Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, 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 Christina Allen at [email protected].


Steven A. Mack
National Commodity Specialist Division