CLA-2-20:OT:RR:NC:N5:228
Luis Trevino
Henan International, Inc.
250 El Camino Real, Ste. 105
Tustin, CA 92780
RE: The tariff classification of Chickpea & Spinach Soup from Spain
Dear Mr. Trevino:
In your letter dated August 12, 2025, you requested a tariff classification ruling.
An ingredients breakdown, manufacturing flowchart, product specification sheet and a picture of the product
accompanied your inquiry.
The subject merchandise, “Chickpea & Spinach Soup,” is described as a ready-to-eat soup consisting of a
mix of chickpeas and cooked vegetables that is packed in 580 ml. glass jars. The product is further described
as safe to eat at an ambient temperature, but it is recommend that it be heated prior to being consumed for
best results. Chickpea & Spinach Soup is said to contain chickpeas, water, spinach, carrots, onion, sunflower
oil, and salt (0.1%).
In your letter, you proposed that the classification of the product may fall under subheading 2104.10.00,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Soups and broths and
preparations therefor. Based upon the ingredients composition, the product will be classified elsewhere.
The applicable subheading for the product, “Chickpea & Spinach Soup,” will be 2005.99.9700, HTSUS,
which provides for other vegetables prepared or preserved otherwise than by vinegar or acetic acid, not
frozen…other vegetables and mixtures of vegetables…other. The general rate of duty will be 11.2 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 Spain will be
subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.20 or exclusion subheading, in
addition to subheading 2005.99.9700, 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/.
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.
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 Timothy Petrulonis at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division