CLA-2-68:OT:RR:NC:N1:128
Ms. Christa Boerlage
Global Horticultural USA, Inc.
4595 Foothill Road
Carpinteria, CA 93013
RE: The tariff classification of mineral wool growing media from Turkey.
Dear Ms. Boerlage:
In your letter dated April 13, 2025, you requested a tariff classification ruling.
The merchandise under consideration are referred to as Begrow Plugs, Begrow Cubes, and Begrow Slabs.
From the information you provided, the Begrow products are made of mineral wool manufactured from
basalt, and are designed and sold as growing media for plants.
The Begrow Plugs are cylindrical in shape and are available in sizes of 2 centimeters in diameter by 2.7
centimeters long, 3.5 centimeters in diameter by 4 centimeters long, and 5 centimeters in diameter by 4
centimeters long. They feature an opening in which a seed is planted for propagation.
The Begrow Cubes are available in a variety of sizes ranging from 10 centimeters long by 10 centimeters
wide by 6.4 centimeters high, to 15 centimeters long by 15 centimeters wide by 14.2 centimeters high. The
center of the cube features a divot in which a seed or seedling is planted. They are designed to be used alone
or in conjunction with the Begrow Plugs, receiving seedlings started in the Plugs.
The Begrow Slabs are available in a variety of sizes ranging from 50 centimeters long by 20 centimeters wide
by 7.5 centimeters high, to 100 centimeters long by 20 centimeters wide by 10 centimeters high. Rather than
being used for direct planting, the Slabs serve as a base for plants started in Plugs, Cubes, or other growing
media. You state that the Slabs may be pre-bored with holes according to the customer’s order, or they may
be imported in a solid block for the customer to cut themselves. The Plugs or Cubes are placed in these holes
so that the plants’ roots can continue to grow.
In your ruling request you suggest classification of the Begrow Plugs, Cubes, and Slabs in heading
6806.90.0090, Harmonized Tariff Schedule of the United States (HTSUS), as other mineral wools, or other
mixtures and articles of heat-insulating, sound-insulating or sound-absorbing materials.? However, the
Begrow products are more specifically provided for elsewhere.?
The applicable subheading for the Begrow Plugs, Begrow Cubes, and Begrow Slabs will be 6806.10.0090,
HTSUS, which provides for ?Slag wool, rock wool and similar mineral wools?:? Slag wool, rock wool and
similar mineral wools (including intermixtures thereof) in bulk, sheets or rolls:? Other:? Other.?? The rate of
duty will be 3.9% 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. 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 6806.10.0090, 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 Nicole Sullivan at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division