CLA-2-38:OT:RR:NC:N1:140
Mr. Roman Titenok
Ecosanis
451 Stonecrop Ct.
Galloway, OH 43119
RE: The tariff classification of Four Cleansing Products for the Dairy Industry from Turkey
Dear Mr. Titenok:
In your letter dated February 08, 2018, you requested a tariff classification ruling.
You requested a Binding Ruling on four different products which are indicated for use in bathing, cleansing, and alleviation of various skin and muscle ailments in animals. The subject products consist of the following four items:
1. FAST TAP Lotion- (gel application) Anti-inflammation lotion.
2. LACTOBONA (lotion) Phytomineral and Anti-mastitis lotion.
3. HooF PRO: (bath application) treatment and prevention of hoof diseases.
4. HooF PRO: (spray application) treatment and prevention of hoof diseases.
A summary of each product is as follows:
Fast Tap Lotion: (gel application) Literature for Fast Tap indicates that it is a lotion that is applied to the area under the udder in a thin layer. The active components in the balm are stated to quickly penetrate through the skin to act synergistically to provide high therapeutic results such as: “Muscle relaxation; Vessels dilation; Local metabolism stimulation; Lymphatic drainage improvements; Swelling reduction; Inflammation reduction.” The active ingredients are listed as: Purified water, kaolin, glycerin, polycarboxylic acids, betaine, allantoin, coconut oil, complex organic salts, tween 80, and THI.”
The LACTOBONA (Phytomineral and Anti-mastitis lotion) is also applied to the udder. Literature you provided indicates that it “Relaxes the muscles; Dilates the vessels; Accelerates the secrecy drainage; Improves the lymphatic drainage; Reduces swelling; … Eliminates the stinging and dryness of the skin; Easy sedative action.”
You indicate that it is used for orthopedic injuries and limb diseases such as bursitis and arthritis. The phytomineral lotion is applied to the udder with a thin layer, then evenly to the entire affected area with a sufficient quantity. It is recommended to apply twice a day after milking until the symptoms disappear. It is imported in 500 mL canisters or laminated 200 mL tubes.
The stated ingredients for Lactobana are: “Purified water, eucalyptus extract, St. John’s wort extract, sabal extract, glycerol, betaine, menthol, turpentine oil, allantoin, dimethylsulfoxide, methyl salicylate, coconut oil, organic salt complex, organic acids complex and THI.”
The HooF PRO: (bath application) is stated to be “used to saturate the limbs with a wide range of trace elements; improve recovery process of the hoof horn; exfoliates dead skin in places disinfectants fail to reach; prevents cracking; stimulates the anti-inflammatory and lymphatic drainage; eliminates swelling and inflammation; accelerates the freeze function in fetlock joints and hooves. HooF PRO is used for the treatment and prevention of hoof diseases in cattle, pigs, goats and sheep.”
It is indicated to be a concentrated bath preparation, which sanitizes, and provides rehabilitation to the limbs of animals. Literature provides the following summary of the product. “It has pronounced bactericidal effect. It additionally helps exfoliate the dead skin which is the pathogenic microflora that is difficult to access for ordinary disinfectants; Prevents cracking; Creates a specific film called salt cloak; stimulates the anti-inflammatory and lymphatic drainage for several hours; … Accelerates the freeze function to the area of the fetlock joints and hooves.”
It is imported in a 10-Liter canister. Active ingredients are stated to be “Purified water, complex organic acids, complex organic salts, crystalline violet, glycerin, tween 80, tannin, BC04, dimethicone, propylene glycol.”
HooF PRO Spray (spray application) as summarized in literature provided is used for “reducing inflammation; treats ulcers and open abscesses; eliminating irritation; eliminating dermatitis; eliminating mild to moderate rashes; promoting exfoliation of dead skin/hooves in hard to reach places where pathogenic bacteria grows; prevents cracking of the hooves/skin; accelerates healing of damaged or infected skin; preventing growth of pathogenic bacteria; repels insects. HooF PRO” Spray is an effective treatment for diseases and injuries to top layer of skin in a domestic animal such as cattle, horses, pigs, sheep, goats, poultry (chickens, turkeys, geese, ducks), dogs and cats.
It is imported in an aluminum aerosol spray can 335 ml. equipped with fine sprayer to ensure uniform application. Active ingredients are stated to be: “Purified water, organic acid complex, organic salt complex, panthenol, crystalline violet, glycerin, tween 80, tannin, dimethicone, propylene glycol, natural repellent complex, THI.”
The applicable subheading for the Four Cleansing Products for the Dairy Industry will be 3307.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other perfumery, cosmetic or toilet preparations, not elsewhere specified or included. The rate of duty will be 5.4 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 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 Paul Hodgkiss at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division