CLA-2-32:OT:RR:NC:N3:136
David Bols
Senso New York, LLC
752 Ramsey Ave
Hillside, NJ 07205
RE: The tariff classification of SENSO RESIN PR4000 HCD-N from the Netherlands
Dear Mr. Bols:
In your letter dated July 30, 2025, you requested a tariff classification ruling on SENSO RESIN PR4000
HCD-N.
The subject product is described as a castor oil–based seamless coating product with the trade name SENSO
RESIN PR4000 HCD-N. The product is a viscous fluid mixture available in various colors. You state that
this product is intended for use as a finished architectural coating, applied to interior floors and walls, with no
additional formulation or processing after import. SENSO RESIN PR4000 HCD-N is chemically based on a
modified natural polymer (castor oil) and includes mineral fillers and pigments. It contains 0.2% organic
solvents (VOC content: 3.8 g/L) and no water.
In response to our subsequent email inquiry, you stated that the subject product is applied to floors and walls
to:
Provide a decorative, design-grade finish
Deliver a continuous, waterproof, and hygienic surface
Serve as the final viable surfacing layer with long-term durability and minimal environmental impact
The applicable subheading for SENSO RESIN PR4000 HCD-N will be 3214.90.5000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Glaziers' putty, grafting putty, resin cements,
caulking compounds and other mastics; painters' fillings; nonrefractory surfacing preparations for facades,
indoor walls, floors, ceilings or the like: Other: Other. The general rate of duty will be 3.25 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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of percent minus the column 1-General duty
rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification,
i.e. 9903.02.19, in addition to subheading 3214.90.5000, HTSUS, listed above.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which
are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by
contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone
at (202) 554-1404, or by visiting their website at www.epa.gov.
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