CLA-2-29:OT:RR:NC:N3:138
Allen Gu
Longene Limited
8 Barstow Rd, 1B
Great Neck, NY 11021
RE: The tariff classification of Berberine Hydrochloride 97% (CAS No. 633-65-8) in bulk powder form,
from China
Dear Mr. Gu:
In your letter dated November 18, 2025, you requested a tariff classification ruling. We apologize for the
delay as the information was submitted to our laboratory for analysis.
Berberine Hydrochloride is the hydrochloride salt form of berberine, an isoquinoline alkaloid. You indicated
the product will be extracted from Coscinium fenestratum as a high purity isolated alkaloid greater than or
equal to 97%.
In your letter, you suggested classification in subheading 2932.99.90, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “heterocyclic compounds with oxygen hetero-atom(s) only:
Other: Other: Other.” We disagree. Berberine Hydrochloride is a vegetal alkaloid and will be classified as
such.
The applicable subheading for the Berberine Hydrochloride 97% in bulk powder form will be 2939.79.0000,
HTSUS, which provides for “Alkaloids, natural or reproduced by synthesis, and their salts, ethers, esters and
other derivatives: Other, of vegetal origin: Other.” The general rate of duty will be free.
This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health
Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are
administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and
Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by
visiting their website at www.fda.gov.
The 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 ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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.
Your submission also appears to indicate that the berberine hydrochloride is the same compound as berberine
chloride dihydrate (CAS 5956-60-5). However, according to our laboratory, these two products are not the
same. If you are also requesting a classification ruling for the berberine chloride dihydrate, please provide a
complete component breakdown by weight of all ingredients totaling 100 percent. Include the purpose and
function of each ingredient. If you decide to resubmit your request, please include all of the material that we
have returned to you and re-submit your request and the additional information electronically via the
following link: https://erulings.cbp.gov/s/.
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 Judy Lee at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division