CLA-2-20:OT:RR:NC:N5:228
Steven Zisser
Zisser Customs Law Group
9355 Airway Road, Suite 1
San Diego, CA 92154
RE: The tariff classification of a coconut preparation from Thailand
Dear Mr. Zisser:
In your letter dated April 8, 2025 you requested a tariff classification ruling on behalf of your client, Laird
Superfood, Inc.
An Ingredients breakdown, a description of the manufacturing process, and a picture of the product
accompanied your inquiry.
The subject merchandise is described as a coconut milk powder that is said to contain approximately 98
percent raw coconut milk and 2 percent tapioca maltodextrin. The product is said to be prepared by grinding
the flesh of the coconut and pressing with water to create what is said to be a coconut cream (or coconut
milk, used interchangeably and variable in fat content). This coconut cream contains no other additives and is
100 percent coconut, containing the naturally occurring coconut oil, as it is not further processed or refined.
Additional processing steps include pasteurizing the pure coconut cream, followed by adding tapioca
maltodextrin (starch) which allows the coconut cream to flow into the spray dryer. Concluding steps include
homogenizing the coconut cream, spray-drying, and packaging for import to the United States in 15 Kg.
containers. The coconut milk powder is intended to be used to make coffee creamers, instant lattes, drink
mixes, supplements, snack foods, etc., and will be sold through the client’s website, Amazon, and various
grocery stores.
The applicable subheading for coconut milk powder will be 2008.19.1500, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for fruit, nuts and other edible parts of plants, otherwise prepared
or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere
specified or included … nuts, peanuts (ground-nuts) and other seeds, whether or not mixed together … other,
including mixtures … coconuts. The general rate of duty will be 1 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, including Thailand, will be subject to an additional 10 percent ad valorem rate of duty. At the time
of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in
addition to subheading 2008.19.1500, 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 on the World Wide Web at https://hts.usitc.gov/current.
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.
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 Timothy Petrulonis at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division