CLA-2-38:OT:RR:NC:N 3:139
Michael Hensley
TBI Brokers Incorporated
420 Brave Heart Loop
Bozeman, MT 59718
RE: The tariff classification of cosmetic ingredients from India
Dear Mr. Hensley:
In your letter, made on behalf your client Ampak Company Incorporated, dated May 30, 2025, you requested
a tariff classification ruling.
The instant merchandise is a group of cosemetic ingredients that go under the brand name "SALIGUARD"
Saliguard® BDHA is a paraben free preservative. It consists of benzyl alcohol, dehydroacetic acid, and
water.
Saliguard® EZ is a multi-functional, paraben free blend. It consists of propanediol and ethylhexylglycerin.
Saliguard® HDZ is a multifunctional, broad spectrum additive specially designed for microbiological
preservation and moisturization of cosmetics preparations. It consists of 1,2-hexanediol, 1,3-propanediol, and
iodopropynyl butylcarbamate.
Saliguard® Ultima 2 is a anti-microbial agent and preservative. It consists of gluconolactone, calcium
gluconate, and potassium sorbate.
Saliguard® UZB is a paraben, formaldehyde, and isothiazolinone free system that is designed to replace
parabens in personal care and cosmetic formulations. It consists of undecylenic acid, 1,3-propanediol, and
benzyl alcohol.
The applicable subheading for Saliguard® BDHA, and Saliguard® UZB will be 3824.99.2900, 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: Mixtures containing
5 percent or more by weight of one or more aromatic or modified aromatic substances: Other. The rate of
duty will be 6.5 percent ad valorem.
The applicable subheading for Saliguard® EZ, Saliguard® HDZ, and Saliguard® Ultima 2 will be
3824.99.9397, 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. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. However, your products falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your
products classification, 9903.01.32, in addition to subheadings 3824.99.2900 and 3824.99.9397, HTSUS,
listed above.
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 John Bobel at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division