CLA-2-29:OT:RR:NC:N3:138
Robyn Brunciak
Interchem Corp
120 Route 17 North
Paramus, NJ 07652
RE: The tariff classification of Cannabidiol (CAS No. 13956-29-1) in bulk powder form, from Spain
Dear Mrs. Brunciak:
In your letter dated March 27, 2025, you requested a tariff classification ruling.
Cannabidiol (CBD) is a phytocannabinoid indicated for the treatment of seizures associated with
Lennox-Gastaut Syndrome or Dravet Syndrome in patients 2 years of age and older. In a follow-up email to
this office, you stated Cannabidiol is an active pharmaceutical ingredient imported for R&D study.
The applicable subheading for the Cannabidiol imported in bulk powder form will be 2907.29.9000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Polyphenols;
phenol-alcohols: Other: Other.” The rate of duty will be 5.5 percent ad valorem. Currently, Cannabidiol is not
listed in the Pharmaceutical Appendix to the Tariff Schedule.
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/.
This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health
Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are
administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and
Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by
visiting their website at www.fda.gov.
This merchandise may also be subject to the requirements of the Controlled Substances Act, which are
enforced by the U.S. Drug Enforcement Administration (DEA), Office of Diversion Control. You may
contact them at 2401 Jefferson Davis Highway, Alexandria, VA 22301, telephone (800) 882-9539.
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 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 Judy Lee at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division