CLA-2-34:OT:RR:NC:N3:136
Kendra Highlands
QVC
1200 Wilson Drive
West Chester, PA 17055
RE: The tariff classification of Hydrating Body Wash from Vietnam
Dear Ms. Highlands:
In your letter dated June 16, 2025, you requested a tariff classification ruling on Hydrating Body Wash.
You identify the subject product as QVC Item # H496450, HomeWorx by Slatkin & Co., S/2 34oz Hydrating
Body Wash. You state that this product is in liquid form and intended to be used as a soap for washing the
skin. Your submission indicates that this product will be marketed and sold as a body wash, packaged for
retail sale in a disposable plastic bottle with a dispensing pump. You describe that the body wash is infused
with essential oils to deliver a rich lather to gently cleanse, refresh, and hydrate skin. The Hydrating Body
Wash contains sodium laureth sulfate (a surface-active-agent), and several other ingredients.
In your submission, you suggest classification in subheading 3401.30.1000, Harmonized Tariff Schedule of
the United States (HTSUS); however, we have found that to be incorrect because while benzyl alcohol is an
aromatic chemical compound, it is not a surface-active agent.
The applicable subheading for the Hydrating Body Wash will be 3401.30.5000, HTSUS, which provides for
Organic surface-active products and preparations for washing the skin, in the form of liquid or cream and put
up for retail sale, whether or not containing soap: Other. The general rate of duty will be free.
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. 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
3401.30.5000, 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 Nuccio Fera at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division