CLA-2-16:OT:RR:NC:N5:231
Mr. Giacomo Cinelli
Giacinto Callipo Conserve Alimentari srl
Via Riviera Prangi 156
Pizzo, 89812 Calabria
Italy
RE: The tariff classification of Yellowfin Tuna Fillets from Italy
Dear Mr. Cinelli:
In your letter dated November 7, 2025, you requested a tariff classification.
The subject merchandise is Yellowfin Tuna Fillets in Seawater (Thunnus albacares). You state that raw
yellowfin tuna is frozen, trimmed to remove the belly portion, and then the belly meat is thawed and
steam-cooked in an autoclave. The cooked fillets are placed into six-ounce jars by hand and covered with
seawater heated to 70° Celsius. The jars are then sealed. The finished product which contains only tuna (70
percent) and seawater, is then shipped to distributors and retailers in the United States.
The applicable subheading for the above-described tuna, if entered while the tariff-rate quota remains open,
will be 1604.14.2299, Harmonized Tariff Schedule of the United States (HTSUS), which provides for:
“Prepared or preserved fish…: fish, whole or in pieces but not minced: tunas, skipjack and bonito (Sarda
spp.): Tunas and skipjack: In airtight containers: Not in oil: In containers weighing with their contents not
over 7 kg each, and not the product of any insular possession of the United States, for an aggregate quantity
entered in any calendar year not to exceed 4.8 percent of apparent United States consumption of tuna in
airtight containers during the immediately preceding year, as reported by the National Marine Fisheries
Service: Other: Other.” The rate of duty will be 6 percent ad valorem.
The applicable subheading for the above-described product, if entered after the tariff-rate quota has closed,
will be 1604.14.3099, HTSUS, which provides for: “Prepared or preserved fish…: fish, whole or in pieces
but not minced: Tunas, skipjack and bonito (Sarda spp.):Tunas and skipjack: In airtight containers: Not in oil:
Other: Other: Other.” The rate of duty will be 12.5 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 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 1604.14.2291 or 1604.14.3099, HTSUS, listed
above.
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 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 the 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 Title 19 of the Code of Federal Regulations
(19 C.F.R. Part177).
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 Ekeng Manczuk at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division