CLA-5-21:OT:RR:NC:N5:231
Mr. Clay Short
Transnetyx, Inc.
8110 Cordova Road
Cordova, TN 38016
RE: The tariff classification of Human Fecal Specimens from Various Countries
Dear Mr. Short:
In your letter dated August 26, 2025, you requested a tariff classification ruling.
The subject merchandise is human fecal specimens. You state that the specimens will be used for scientific
testing for DNA sequencing purposes. You further state the specimens will originate from Australia,
European Union, Switzerland, and United Kingdom. The specimens will be safely imported at room
temperature in a plastic device, sealed with a screw top cap, sealed in a bag, and then placed in an outer pack,
envelope, or box.
You have sought classification in subheading 9705.21.0000, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for: “Collections and collectors’ pieces of zoological, botanical,
mineralogical, anatomical or paleontological interest: human anatomical specimens and parts thereof.” We
disagree. The subject merchandise is designed to be further examined, analyzed, dissected, or otherwise
adulterated for laboratory research and diagnostic purposes, not used for preservation or display. As such,
classification in Chapter 97 is precluded..
The applicable subheading for the Human Fecal Specimens will be 0511.99.4070, HTSUS, which provides
for: “Animal products not elsewhere specified or included; dead animals of chapter 1 or 3, unfit for human
consumption: Other: Other: Other: Other.” The rate of duty will be 1.1 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 from Australia 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, i.e., 9903.01.25, in addition to subheading
0511.99.4070, HTSUS, listed above. 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 15 percent minus the Column 1 – General rate of duty. 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 0511.99.4070, HTSUS, listed above. At this time products from Switzerland will be
subject to an additional 39 percent ad valorem rate of duty. At the time of entry, you must report the Chapter
99 heading applicable to your product classification, i.e., 9903.02.58, in addition to subheading
0511.99.4070, HTSUS, listed above. At this time products from the United Kingdom 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, i.e., 9903.02.66, in addition to subheading 0511.99.4070, 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 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 Regulations (19 C.F.R. 177).
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 control number indicated above should be provided with the entry documents filed at
the time this merchandise is imported. If you have questions regarding the ruling, contact National Import
Specialist Ekeng Manczuk at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division