CLA-2-38:OT:RR:NC:N3:139
Andy Lee
D&A Customs Services Incorporated
152 W Walnut Street, Suite 260
Gardena, CA 90248
RE: The tariff classification of a premix powder from Korea
Dear Mr. Lee:
In your letter dated March 29, 2025, you requested a tariff classification ruling on behalf of your client, US
Pharmatech Incorporated.
The item under review is “L-Citrulline DL-Malate 2:1 premix powder”, a combination of citrulline and malic
acid in a powdered form. You state that this powder will be used as an ingredient in a dietary supplement.
You suggest classification in subheading 2924.19, HTSUS, which provides for Carboxyamide-function
compounds; amide-function compounds of carbonic acid: Acyclic amides (including acyclic carbamates) and
their derivatives; salts thereof: Other. We disagree. The L-Citrulline DL-Malate 2:1 premix powder is not a
separate chemically defined organic compound as defined in Chapter 29 Note 1. Therefore, it is excluded
from Chapter 29.
The applicable subheading for the L-Citrulline DL-Malate 2:1 premix powder will be 3824.99.9397,
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: Other:
Other: Other: Other. The rate of duty will be 5 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your
product classification, 9903.01.32, in addition to subheading 3824.99.9397, HTSUS, listed above.
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/.
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 John Bobel at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division