CLA-2-32:OT:RR:NC:N3:136
Chrysa Soulantoni
Brilliant Group Inc.
750 National Court Suite 100
Richmond, CA 94804
RE: The tariff classification of Basic Violet Dye 11:1 from China
Dear Ms. Soulantoni:
In your letter dated May 20, 2025, you requested a tariff classification ruling on Basic Violet Dye 11:1.
In your request, the subject product is identified as Basic Violet Dye 11:1. The provided Safety Data Sheet
indicates that Basic Violet Dye 11:1 is a yellow-brown powder. The assigned Chemical Subtract Service
(CAS) number is 73398-89-7. Basic Violet Dye 11:1 is a fluorescent dye primarily used as a colorant in
commercial applications such as in ink production and dyeing materials like cotton, wool, and silk. It is a
cationic dye from the Xanthene family, known for its bright pink/red color and strong green fluorescence
when dissolved in water.
In your request, you suggest classification in subheading 3204.13.1000, Harmonized Tariff Schedule of the
United States (HTSUS); however, we have found this to be incorrect because subheading 3204.13.1000,
HTSUS, does not specifically include Basic Violet Dye 11:1.
The applicable subheading for the Basic Violet Dye 11:1 will be 3204.13.8000, HTSUS, which provides for:
Synthetic organic coloring matter, whether or not chemically defined; preparations as specified in note 3 to
this chapter based on synthetic organic coloring matter; synthetic organic products of a kind used as
fluorescent brightening agents or as luminophores, whether or not chemically defined: Synthetic organic
coloring matter and preparations based thereon as specified in note 3 to this chapter: Basic dyes and
preparations based thereon: Other: Other. The general rate of duty will be 6.5 percent ad valorem.
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 3204.13.8000, 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. At this time products from all 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 3204.13.8000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 3204.13.8000, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 3204.13.8000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status
of goods covered by the Notice cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-China, respectively.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which
are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by
contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone
at (202) 554-1404, or by visiting their website at www.epa.gov.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Nuccio Fera at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division