Mr. Naga Bhushan Mandava
Repar Corporation
8070 Georgia Avenue, Suite 209
Silver Spring, MD 20910

RE: The tariff classification of Homobrassinolide (1%) from India

Dear Mr. Mandava:

In your letter dated July 04, 2019, you requested a tariff classification and country of origin ruling.

The instant product consists of a chemical substance called Homobrassinolide which is (in-part) diluted, and mixed with citric acid, propylene glycol, and castor oil ethoxylate. The active ingredient is (2a,3a,22S,23S,24S)-2,3,22,23-Tetrahydroxy-24-ethyl-ß-homo-7-oxa-5a-cholestan-6-one). It is also known as 22S,23S-homobrassinolide and CAS # 80483-89-2. You indicate that it is a steroid/hormone. It is mainly used as a plant growth regulator.

You have suggested classification under HTSUS Heading 2937. We disagree. The Explanatory Notes for Heading 2937 exclude products used as “Plant-growth regulators (e.g., phytohormones), natural or synthetic.”

The applicable subheading for the Homobrassinolide (1%) will be 3808.99.9501, 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 or articles (for example, sulfur-treated bands, wicks and candles, and flypapers): Other: Herbicides, anti-sprouting products and plant-growth regulators: Containing any aromatic or modified aromatic herbicide, anti-sprouting agent or plant-growth regulator: Other.” The rate of duty will be 5 % ad valorem.

This merchandise may be subject to the requirements of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), which are administered by the U.S. Environmental Protection Agency, Office of Pesticide Programs. Information on the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) can be obtained by contacting the National Pesticide Information Center (NPIC) at 1-800-858-7378, or by visiting the EPA website at

You also requested a review for Country of Origin purposes. You indicated that the origin of the finished product is India. However you have not provided sufficient information for us to make a determination for origin of the instant product. We need to know where the active ingredient is synthesized. We also need to know where (in which country) each ingredient is from, and where each step in the manufacturing process occurs. If you still wish a determination for origin purposes you may submit a request for a ruling with that additional information.

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 Paul Hodgkiss at [email protected].


Steven A. Mack
National Commodity Specialist Division