CLA-2-38:OT:RR:NC:N:3:139
Jamie Palios
Itochu International Incorporated
1251 Avenue of the Americas, 51st Floor
New York, NY 10020
RE: The tariff classification of a powder coating from Japan
Dear Mr. Palios:
In your letter dated July 16, 2025, and an earlier submission, you requested a tariff classification ruling.
The merchandise under review is a powder coating consisting of barium titanate, diniobium pentaoxide, and
trontium titanate. You state that this product will be used for powder coating applications primarily for
coating trailers and similar items. In your submission, you suggest classification in subheading 2816.40.2000,
Harmonized Tariff Schedule of the United States (HTSUS); however, we have found that to be incorrect.
Pursuant to Chapter 28 Note 1, the described chemical mixture is precluded from this chapter.
The applicable subheading for the powder coating will be 3824.99.3990, 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 of two or more inorganic
compounds: 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, 9903.01.25 in addition to subheading
3824.99.3990, 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)
James Forkan
Acting Director
National Commodity Specialist Division