Mr. Barry Finnegan
Horseware Products, Ltd.
Fred Hunneeke Building
1350 Cunningham Road
Kinston, NC 28501
RE: The tariff classification of "RugSafe Cotton Fresh Rug Wash," "RugSafe Fleece Wash," "RugSafe Merino and Wool Wash," "RugSafe Numnah, Boot and Bandage Wash," and "RugSafe Sheepskin Conditioner" from the United Kingdom
Dear Mr. Finnegan:
In your ruling request dated October 15, 2019, you requested a tariff classification ruling on "RugSafe Cotton Fresh Rug Wash," "RugSafe Fleece Wash," "RugSafe Merino and Wool Wash," "RugSafe Numnah, Boot and Bandage Wash," and "RugSafe Sheepskin Conditioner."
Your submission describes four of the five products at issue as natural washes, produced for the equine industry to wash horse rugs, apparel, clothing, and accessories, using environmentally friendly formulations, packaging, and ethos. "RugSafe Cotton Fresh Rug Wash," "RugSafe Fleece Wash," "RugSafe Merino and Wool Wash," and "RugSafe Numnah, Boot and Bandage Wash" are washing preparations, containing non-ionic surfactants and other substances.
"RugSafe Sheepskin Conditioner" is described as a leather oiling agent for treatment of leather and suedes in wetcleaning and for re-oiling cleaned leather in a spraying process.
You state that the subject products will be imported in 500 milliliter, 1 liter, and 2.5 liter containers and are not put up for retail sale upon importation into the United States.
The applicable subheading for "RugSafe Cotton Fresh Rug Wash," "RugSafe Fleece Wash," "RugSafe Merino and Wool Wash," and "RugSafe Numnah, Boot and Bandage Wash" will be 3402.90.5010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Other: Other: Other: Washing preparations. The general rate of duty will be 3.7 percent ad valorem.
The applicable subheading for "RugSafe Sheepskin Conditioner" will be 3403.91.5000, HTSUS, which provides for Lubricating preparations (including cutting-oil preparations, bolt or nut release preparations, antirust or anticorrosion preparations and mold release preparations based on lubricants) and preparations of a kind used for the oil or grease treatment of textile materials, leather, furskins or other materials, but excluding preparations containing, as basic constituents, 70 percent or more by weight of petroleum oils or oils obtained from bituminous minerals: Other: Preparations for the treatment of textile materials, leather, furskins or other materials: Other. The general rate of duty will be 6.5 percent ad valorem.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency (EPA). Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at (202) 554-1404, by e-mailing to email@example.com, or by visiting their website at www.epa.gov.
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 https://hts.usitc.gov/current.
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 Nuccio Fera at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division