Mr. Prashant Khade
NextGen BioProducts
6076 Corte Del Cedro
Carlsbad, CA 92011

RE: The tariff classification of a Mini Plasmid Isolation Kit from India

Dear Mr. Khade:

In your letter dated November 25, 2020, you requested a tariff classification ruling. This ruling request was submitted to our laboratory for review. We apologize for the delay.

The merchandise in question is a Mini Plasmid Isolation Kit. You state that these kits can efficiently extract and purify plasmid DNA from bacteria. The purified plasmid DNA is suitable for basic molecular biology techniques like restriction digestion, PCR amplification, sequencing etc. The kit contains the following: Bovine Pancreatic Ribonuclease A (RNase A) Spin column containing a silica gel membrane Lysis buffer Two wash buffers Elution buffer Resuspension buffer Neutralization buffer Collection tubes

Additionally, you state that the isolation procedure is based on the following steps: 1. Prior to the beginning of the procedure, the RNaseA is added to the suspension buffer, and ethanol is added to the two wash buffers. 2. The sample is placed in the suspension buffer and mixed, the lysis buffer is then added and the sample is mixed again. 3. The sample is centrifuged, placed in a spin column containing a silica membrane to which the DNA molecules bind. The spin column is then centrifuged, and the two separate wash buffers are added, with any flow through & excess salt removed. The sample is then centrifuged again to remove excess wash buffer. 4. The elution buffer is then added to the spin column and allowed to briefly incubate. The spin column is then centrifuged again. Purified DNA has then been eluted.

Based upon the information you have provided us, these three kits use a spin column-based nucleic acid purification system to purify nucleic acids. This method relies on the fact that nucleic acid will bind to the silica gel solid phase membrane under certain conditions. Based upon our laboratory review, the Mini Plasmid Isolation Kit is used to extract and purify bacterial DNA using an adsorption chromatography process, a fundamentally physical application versus a specific chemical reaction.

The applicable subheading for the Mini Plasmid Isolation Kit will be 3824.99.9297, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other. The rate of duty will be 5 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 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 John Bobel at [email protected].


Steven A. Mack
National Commodity Specialist Division