CLA-2-18:OT:RR:NC:N5:231

Jeremy Page, Esq.
Page Fura, P.C.
939 W. North Avenue
Suite 750
Chicago, IL 60642

RE: The tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) for a Chocolate Preparation

Dear Mr. Page:

In your letter dated July 6, 2025, you requested a ruling on the tariff classification and eligibility under the USMCA of a Chocolate Preparation on behalf of your client, Clasen Quality Chocolate, Inc. (Madison, WI). An ingredients breakdown, production description, product specifications, and representative images of the product container accompanied your inquiry.

The subject merchandise is described as a Chocolate Preparation. The ingredients are said to be 99 percent chocolate liquor and 1 percent sugar. The chocolate liquor is stated to be manufactured in Ivory Coast, Ghana, Nigeria, Cameroon, Ecuador, Peru, and/or Brazil. The origin of the sugar is not stated. Once produced, the liquor will be exported to Canada for granulated sugar to be added and establish the required 99 to 1 percent ratio. After mixing occurs in Canada, the finished preparation will be shipped to the United States in a melted state of approximately 40,000 lbs. as stored in liquid tanker trucks, or in a solid state as 10 lb. blocks packaged in 2,000 lb. totes or larger one metric ton blocks.

Classification:

The applicable subheading for the Chocolate Preparation will be 1806.20.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “Chocolate and other food preparations containing cocoa: Other preparations in blocks, slabs or bars, weighing more than 2 kg or in liquid, paste, powder, granular or other bulk form in containers or immediate packings, of a content exceeding 2 kg: Preparations consisting wholly of ground cocoa beans, with or without added cocoa fat, flavoring or emulsifying agents, and containing not more than 32 percent by weight of butterfat or other milk solids and not more than 60 percent by weight of sugar: Other: Other.” The general rate of duty will be 4.3 percent ad valorem. Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S. Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to subheading 1806.20.5000, HTSUS, listed above. Articles that are entered free of duty under the terms of general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to subheading 1806.20.5000, HTSUS.

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. the 9903.01.26 exclusion subheading, in addition to subheading 1806.20.5000, HTSUS, listed above.

The tariffs and additional duties cited herein 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/.

USMCA:

The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020 of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”) 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states the following:

For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a “good originating in the territory of a USMCA country” only if –

(i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o));

Production of the Chocolate Preparation in Canada results in an originating good from a USMCA Rules of Origin perspective. For goods classified under subheading 1806.20.5000, HTSUS, the applicable Rule of Origin requires the following: “A change to subheading 1806.20 from any other heading.” In the case of the instant product, this requirement is met.

The granulated sugar in the finished product has been produced from cane or beet sugar that is classified in heading 1701, HTSUS, a classification in a heading other than Heading 1806. The chocolate liquor in question is said to be pure, comprised exclusively of the cocoa beans from which it has been ground. In this case, the liquor is similarly said to be cocoa liquor or cocoa paste, the latter of which is classified in subheading 1803.10.0000, HTSUS if not defatted, or in subheading 1803.20.0000, HTSUS if wholly or partly defatted. In either case, the classification of the chocolate liquor under in heading 1803 puts it in a heading other than 1806. As such, and coupling this with classification of the granulated sugar in Heading 1701, the requisite change in classification occurs consistent with USMCA’s Rules of Origin and results in a USMCA originating good.

Based on the facts provided, the chocolate preparation qualifies for USMCA preferential treatment because it meets the requirements of HTSUS General Note 11(b)(iii). The merchandise will therefore be entitled to a free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and agreements.

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 merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling FDA at (301) 575-0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html.

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 Frank Troise at [email protected].

Sincerely,

(for)
James Forkan
Acting Director
National Commodity Specialist Division