CLA-2-13:OT:RR:NC:N231
Ms. Sarah Höelzl
Höelzl LLC
1032 Sixth Street, Unit 2
Santa Monica, CA 90403
RE: The tariff classification of Pet Supplement Extracts from Germany
Dear Ms. Höelzl:
In your letter dated April 22, 2024, you requested a tariff classification ruling. A processing flow chart, product ingredients list, and product sample were included with your request.
The subject merchandise consists of five Pet Supplement Extracts, known alternatively as Gemmo Extracts or Gemmo Macerates, that have the Purple Stars brand name. The products, said to be intended for use in dogs or cats as natural feed supplements, are extracted by using a glycerin, alcohol, and water solution. The bulk liquid extracts are filled into 30 ml. (1 oz.) brown glass bottles, sealed with pipettes, and shipped 150 bottles per carton. They will primarily be sold online in single units though the company’s website and Amazon, and consist of five formulations, as described below.
“Calm” Purple Stars Pet Supplement Extract is said to be a natural calming remedy for dogs. It is a colorless essence of plant buds and shoots derived from apple, silver lime, fig, olive, and hawthorn trees, which is then mixed with the inactive ingredients aqua purificata demineralized water (20.7 percent volume alcohol) and vegetable glycerine.
“Move” Purple Stars Pet Supplement Extract is said to maximize canine joy in movement for dogs. It is a colorless essence of plant buds and shoots derived from silver fir, black currant, common juniper, dog rose, and silver lime trees, which is then mixed with the inactive ingredients aqua purificata demineralized water (24.6 percent volume alcohol) and vegetable glycerine.
“Glow” Purple Stars Pet Supplement Extract is said to be an elixir for skin and shiny coat for dogs. It is a colorless essence of plant buds and shoots derived from silver lime, common juniper, rosemary, silver birch, and silver fir trees, which is then mixed with the inactive ingredients aqua purificata demineralized water (26.8 percent volume alcohol) and vegetable glycerine.
“Shine” Purple Stars Pet Supplement Extract is said to be an elixir for skin and shiny coat for cats. It is a colorless essence of plant buds and shoots derived from silver lime, common juniper, rosemary, silver birch, and silver fir trees, which is then mixed with the inactive ingredients aqua purificata demineralized water (26.8 percent volume alcohol) and vegetable glycerine.
“Relax” Purple Stars Pet Supplement Extract is said to be a natural calming remedy for cats. It is a colorless essence of plant buds and shoots derived from apple, silver lime, common fig, olive, and hawthorn trees, which is then mixed with the inactive ingredients aqua purificata demineralized water (20.7 percent volume alcohol) and vegetable glycerine.
The applicable subheading for the above-described Pet Supplement Extract products will be 1302.19.9140, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “Vegetable saps and extracts: Other: Other: Other.” The 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 at https://hts.usitc.gov/current
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling FDA at 301-575-0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Ekeng Manczuk at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division