CLA-2-32:OT:RR:NC:N3:136
William Matthews
Thompson Hine LLP
1919 M Street, Suite 700
Washington, DC 20036
RE: The tariff classification of Complex Inorganic Color Pigments from Japan or Indonesia
Dear Mr. Matthews:
In your letter dated August 20, 2025, on behalf of your client, TOMATEC America, Inc., you requested a
tariff classification ruling on complex inorganic color pigments.
The subject products are described as Complex Inorganic Color Pigments (CICPs), which are used as
coloring matter in numerous industries such as plastics, construction materials, glass, and ceramics. These
CICPs are manufactured in Japan or Indonesia.
You state that CICPs are manufactured by calcining inorganic metal oxides at very high temperatures (over
800 degrees Celsius). The resulting crystal structure creates a highly stable, weather and chemical-resistant,
environmentally friendly pigment. The CICPs at issue are identified as follows:
1. Pigment Brown 24 - CAS 68186-90-3, (Ti, Sb, Cr) O2, Titanium Dioxide 75%
2. Pigment Yellow 53 - CAS 8007-18-9, (Ti, Sb, Ni) O2, Titanium Dioxide 80%
3. Pigment Brown 48 - CAS 12789-64-9, (Fe2, Ti, O5) Al203, Titanium Dioxide 60%
4. Pigment Yellow 189 - CAS 69011-05-8, (Ti, W, Ni) O2, Titanium Dioxide 80%
5. Pigment Green 50 - CAS 68186-85-6, (Co, Ni, Zn) 2TiO4, Titanium Dioxide 35%
The applicable subheading for Pigment Yellow 53 and Pigment Yellow 189 will be 3206.11.0000,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other coloring matter;
preparations as specified in note 3 to this chapter, other than those of heading 3203, 3204 or 3205; inorganic
products of a kind used as luminophores, whether or not chemically defined: Pigments and preparations
based on titanium dioxide: Containing 80 percent or more by weight of titanium dioxide calculated on the dry
matter. The general rate of duty will be 6 percent ad valorum.
The applicable subheading for Pigment Brown 24, Pigment Brown 48, and Pigment Green 50 will be
3206.19.0000, HTSUS, which provides for Other coloring matter; preparations as specified in note 3 to this
chapter, other than those of heading 3203, 3204 or 3205; inorganic products of a kind used as luminophores,
whether or not chemically defined: Pigments and preparations based on titanium dioxide: Other. The general
rate of duty will be 6 percent ad valorum.
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, your products fall within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.32, in addition to subheadings 3206.11.0000 and 3206.19.0000, 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 (EPA). Information on the TSCA can be
obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and
Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C.,
20460, by calling the Toxic Substances Control Act Hotline at 800-471-7127, by e-mailing to
[email protected], 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)
Denise Faingar
Acting Director
National Commodity Specialist Division