CLA-2-39:OT:RR:NC:N5: 137
Jong Wook Kim
Unione Customs Clearance & Consulting Firm
18, Hakdong-ro 31-gil, Gangnam-gu, Seoul, Republic of Korea
Seoul N/A
Korea, South
RE: The tariff classification of a polyethylene packaging tube from Korea
Dear Mr. Kim:
In your letter dated July 3, 2025, you requested a tariff classification ruling on behalf of your client, Yonwoo
Co. Ltd.
Model NT19-DPR is identified as a dropper tube sleeve. The tube is composed of polyethylene. The tube will
be imported empty with the bottom unsealed. The tube incorporates a spiral shaped head to allow for the
attachment of a lid after importation. After importation the tube will be filled with a cosmetic product and the
bottom will be sealed.
In your request, you state that you believe this dropper tube sleeve would be correctly classified under
subheading 3926.90.9989, Harmonized Tariff Schedule of the United States (HTSUS), as an other article of
plastic. We disagree. We look to New York ruling N014655, dated August 17, 2007, and hold the opinion
that this product is similar enough that it would also be appropriately classified under heading 3923. As it
would be specified or included elsewhere, it would be excluded from classification under heading 3926.
The applicable subheading for the polyethylene packaging tube will be 3923.90.0080, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for articles for the conveyance or packing of goods,
of plastics: other: other. The general rate of duty will be 3 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,
including Korea, 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 3923.90.0080, 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 Christina Allen at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division