CLA-2-28:OT:RR:NC:N3:36
Semyon Melamed
Alvos International LLC
3726 Las Vegas Boulevard S, Suite 702 W
Las Vegas, NV 89158
RE: The tariff classification of Monopotassium Phosphate from Russia
Dear Mr. Melamed:
In your letter dated October 19, 2025, you requested a tariff classification ruling on Monopotassium Phosphat
e.
You identify the subject product as Monopotassium Phosphate (potassium dihydrogen phosphate, potassium
phosphate monobasic), CAS number 7778-77-0, with a chemical formula of KH2PO4. Monopotassium
Phosphate is a solid inorganic compound, which is odorless, colorless or white in color, and water soluble.
In your submission, you suggest classification in subheading 2835.24.0000, Harmonized Tariff Schedule of
the United States (HTSUS) or subheading 3105.60.0000, HTSUS. Classification in subheading
3105.60.0000, HTSUS, is incorrect, because Chapter Note 1(b) to Chapter 31, excludes separately chemically
defined compounds, with few exceptions, from this chapter.
The applicable subheading for Monopotassium Phosphate will be 2835.24.0000, HTSUS, which provides for
Phosphinates (hypophosphites), phosphonates (phosphites) and phosphates; polyphosphates, whether or not
chemically defined: Phosphates: Of potassium. The Column 2 rate of duty will be 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 Russia will be
subject to an additional ad valorem rate of duty of 10 percent. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.29, in addition to subheading 2835.24.0000, 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 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 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division