Ms. Kristen L. Mazzara
Uniglobe Kisco, Inc.
7588 Central Park Blvd., Suite 204
Mason, OH 45040

RE: The tariff classification of talc and polypropylene pellets from China

Dear Ms. Mazzara:

In your letter dated July 26, 2018, you requested a tariff classification ruling.

The merchandise under consideration is referred to as KPM-1702TE (CPN-1655). Samples were submitted with your ruling request and will be returned to you.

KPM-1702TE (CPN-1655) is pellets which measure approximately 2 milimeters long by 3 milimeters wide by 2 milimeters high. From the information you provided, they are comprised of crushed natural talc mixed with polypropylene resin and additives. You state that the pellets contain between 65 and 75 percent of talc by weight, between 25 and 35 percent of polyproplyne by weight, and between zero and 2 percent of additives by weight. After importation, the pellets are heated, extruded into shape, then laminated with non-woven fabric in order to manufacture automotive trunk boards.

KPM-1702TE (CPN-1655) is a composite good comprised of different materials that are classifiable in different headings. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 3(b) of the HTSUS provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The talc component provides the essential character of this item.

The applicable subheading for KPM-1702TE (CPN-1655) will be 6815.99.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Articles of stone or other mineral substances…not elsewhere specified or included: Other articles: Other: Talc, steatite and soapstone, cut or sawed, or in blanks, crayons, cubes, disks or other forms.” The general rate of duty will be Free.

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 the World Wide Web 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 Nicole Sullivan at [email protected].


Steven A. Mack
National Commodity Specialist Division