CLA-2-29:OT:RR:NC:N3:138
Alexander Augatis
Global Chemicals Corporation
1201 North Orange Street, Suite 700
Wilmington, DE 19801
RE: The tariff classification of Ascorbic Acid (CAS No. 50-81-7) in bulk powder form, from China
Dear Mr. Augatis:
In your letter dated April 10, 2025, you requested a tariff classification ruling.
Ascorbic Acid, also known as Vitamin C is a water-soluble vitamin essential for various bodily functions
and increases resistance to infections. It is used to prevent and treat scurvy, a disease caused by vitamin C
deficiency. In your letter, you indicated the Ascorbic Acid is U.S. Pharmacopeia (USP) grade.
The applicable subheading for the Ascorbic Acid in bulk powder form will be 2936.27.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Vitamin C (Ascorbic acid) and its
derivatives.” The rate of duty will be free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 2936.27.0000, HTSUS, listed above.
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, i.e. 9903.01.32, in addition to subheading 2936.27.0000, 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/.
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.
In a follow-up email to this office, you also inquired about another product called?directly compressible (DC)
for tableting. We need additional information to make a determination. Please provide a complete component
breakdown by weight of all ingredients totaling 100 percent with the purpose and function of each ingredient.
If you decide to resubmit your request, please include all of the material that we have returned to you and
mail your request to Director, National Commodity Specialist Division, Customs and Border Protection, 201
Varick Street, Suite 501, New York NY 10014, attn: Binding Ruling Request. If your request was submitted
electronically and the information required does not involve sending a sample, you can re-submit your
request and the additional information electronically.
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