CLA-2-21:OT:RR:NC:N5:228
Ivan Miljani
Abela Pharm d.o.o.
Viline Vode BB
Belgrade 11000
Serbia
RE: The tariff classification of a dietary supplement from Serbia
Dear Mr. Miljani:
In your letter dated August 27, 2025, you requested a tariff classification ruling.
An ingredients breakdown, and a picture of the product accompanied your inquiry.
The subject merchandise, “10925 – Exedol Z-Globex,” is described as a dietary supplement for joint health
and mobility support. The subject merchandise is said to contain active ingredients which include
glucosamine, chondroitin, S-adenosyl-L-methionine, vitamin C, manganese and vitamin D. The excipients
which serve as the capsule shell, coloring agent, filler, lubricant and anti-caking agent include hypromellose,
titanium dioxide, cornstarch, talc, magnesium stearate, and silicon dioxide. The product is not the result of a
chemical reaction but is a formulated blend of multiple ingredients that are encapsulated and packaged for
retail sale in blister strips containing 120 capsules per carton. Directions on the product label instruct the
consumer to take up to four capsules daily, preferably in two divided doses.
The applicable subheading for the product, “10925 – Exedol Z-Globex,” will be 2106.90.9998, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for food preparations not elsewhere specified
or included . . . other . . . other . . . other. The general rate of duty will be 6.4 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 Serbia will be
subject to an additional ad valorem rate of duty of 35 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.54 or exclusion subheading, in
addition to subheading 2106.90.9998, 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
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division