CLA-2-16:OT:RR:NC:N5:231
Doug Ridge
Stampede Culinary Partners, Inc.
7351 S 78th Avenue
Bridgeview, IL 60455
RE: The tariff classification of Bovine Meat from Brazil
Dear Mr. Ridge:
In your letter dated March 12, 2026, you requested a tariff classification ruling. In lieu of samples, product
descriptions and manufacturing processes were provided.
The subject merchandise consists of trimmed, whole-muscle cuts of bovine meat, including eye of round, top
sirloin, rib lifter, bottom round flats, and chuck rolls. Prior to exportation to the United States, these cuts
undergo a controlled marination and mechanical processing procedure. The beef is subjected to vacuum
tumbling with a formulated preservative solution designed to penetrate the muscle structure and incorporate
functional ingredients throughout the meat. The solution is applied at an approximate pickup rate of 8 percent
by weight and consists of liquid vinegar, water, salt, sodium tripolyphosphate, garlic powder, and black
pepper. During preparation, the sodium tripolyphosphate is first dissolved in chilled water maintained below
38° Fahrenheit (3.3° Celsius) to ensure proper activation before the remaining ingredients are added.
The vacuum tumbling process, conducted for approximately 20 to 30 minutes, serves both mechanical and
functional purposes. Under vacuum conditions, the tumbling disrupts the muscle structure, promotes
absorption of the marinade, and facilitates extraction of myofibrillar proteins. This allows the ingredients to
be incorporated throughout the meat tissue rather than remaining on the surface. The inclusion of sodium
tripolyphosphate modifies the functional properties of the muscle proteins by increasing ionic strength,
enhancing water-binding capacity, and altering the structural characteristics of the meat. In combination with
vinegar and salt, the formulation provides preservation effects by lowering pH, reducing water activity, and
stabilizing the protein matrix, thereby improving microbial stability during refrigerated storage. After
marination and tumbling, the products are vacuum packaged, placed into corrugated shipping containers, and
exported to the United States in either refrigerated or frozen condition.
You suggested classification of the above-described product in subheading 1602.50.6000, Harmonized Tariff
Schedule of the United States (HTSUS). We agree. Subheading 1602.50.6000 which provides for “Other
prepared or preserved meat, meat offal or blood or insects: Of bovine animals: Other: Other: Other,” is
applicable because the subject bovine meat product is advanced beyond the condition of raw meat of Chapter
2. The merchandise is not merely cut or lightly seasoned, but is subjected to a formulated preservative
treatment consisting of vinegar, salt, sodium tripolyphosphate, and seasonings, followed by vacuum tumbling
that promotes internal absorption of the solution into the muscle tissue. Combining vinegar (acid) and sodium
tripolyphosphate (alkaline) in meat marination alters the physical and functional properties of the meat by
improving water retention capacity, modifying muscle proteins by breaking muscle fiber bonds, and
enhancing microbial stability during refrigerated storage. As a result, the product is considered prepared or
preserved meat of bovine animals of heading 1602, Harmonized Tariff Schedule of the United States
(HTSUS).
The applicable subheading for the above-described Bovine Meat will be 1602.50.6000, HTSUS, which
provides for “Other prepared or preserved meat, meat offal, blood or insects: Of bovine animals: Other: Not
containing cereals or vegetables: Other: Other.” The general rate of duty will be 1.8 percent ad valorem.
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.
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 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 Ekeng Manczuk at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division