CLA-2-31:OT:RR:NC:N3:136
Bianca Redeschi
Wip USA Corp
8337 Via Serena
Boca Raton, FL 33433
RE: The tariff classification of fertilizers from Brazil
Dear Ms. Redeschi:
In your letter dated March 18, 2026, on behalf of your client, Frankental Especialidades Bioquimicas LTD,
you requested a tariff classification ruling on fertilizers.
In your submission, the subject products are described as follows:
1. Aminomix is a mineral mixed fertilizer formulated to supply nitrogen and phosphorus for plant
nutrition and crop development. The formulation also contains amino acids and functional additives
that support nutrient uptake and plant metabolic processes. The product is intended exclusively for
agricultural plant nutrition purposes and does not contain pesticidal active ingredients nor pesticidal
claims. The provided photo of the packaging indicates that Aminomix will be imported in one-liter
plastic containers.
Recommended use: Foliar fertilizer for agricultural crops.
Composition Guaranteed analysis: 3.0% Nitrogen (N), 2.0% Phosphorus (PO).
Additional components: Amino acids, Alkalizing agents, Preservatives.
Main Chemical Components: Urea (Chemical Formula: CHNO, CAS Number: 57-13-6), Phosphoric
Acid (Chemical Formula: HPO, CAS Number: 7664-38-2).
Physical and Chemical Properties: Appearance: Brown liquid, Characteristic Odor, pH: < 5.0,
Density: 1.22 g/mL, Soluble in water.
1. Biofran is a mineral foliar fertilizer formulated to provide nitrogen, phosphorus, and potassium for
plant nutrition. The product also contains amino acids, humic substances, hydrolyzed proteins, and
seaweed extract, which support plant metabolism and crop development. The product is intended
exclusively for agricultural plant nutrition purposes and does not contain pesticidal active ingredients
or pesticidal claims. The provided photo of the packaging indicates that Biofran will be imported in
one-liter plastic containers.
Recommended use: Foliar fertilizer for crop nutrition.
Composition Guaranteed analysis: 3.0% Nitrogen (N), 2.0% Phosphorus (PO), 1.0% Potassium
(KO).
Main chemical components: Urea (Chemical Formula: CHNO CAS Number: 57-13-6), Phosphoric
Acid (Chemical Formula: HPO CAS Number: 7664-38-2, Humic Substances (CAS Number:
1415-93-6).
Additional additives: Amino acids, Seaweed extract, Antifreeze agents, Humic substances,
Hydrolyzed proteins, Preservatives.
Physical and Chemical Properties: Appearance: Brown liquid, Odor: Characteristic, pH: < 5, Density:
1.25 g/mL, Soluble in water.
1. Max Fulvic is an organomineral fertilizer formulated to supply nitrogen, potassium, sulfur, and organic
carbon for plant nutrition. The product contains fulvic acid and organic compounds, which contribute
to nutrient availability, soil improvement, and plant metabolic activity. Max Fulvic can be applied
through foliar application, soil application, or fertigation systems. The product is intended exclusively
for agricultural plant nutrition purposes and does not contain pesticidal active ingredients or pesticidal
claims. The provided photo of the packaging indicates that Max Fulvic will be imported in one-liter
plastic containers.
Recommended use: Foliar fertilizer, soil application, and fertigation.
Composition Guaranteed analysis: 10% Nitrogen (N), 5.0% Potassium (KO), 1.5% Sulfur (S), 20%
Organic Carbon (C).
Main chemical components: Potassium Carbonate (Chemical Formula: KCO, CAS Number:
584-08-7), Urea (Chemical Formula: (NH)CO, CAS Number: 57-13-6).
Additional additives: Fulvic acid, Stabilizing agents.
Physical and Chemical Properties: Appearance: Brown liquid, Characteristic Odor, pH: > 7, Density:
1.33 g/mL, Soluble in water.
1. Mega is a mineral mixed fertilizer formulated to provide macro and micronutrients for plant nutrition.
The product supplies nitrogen, phosphorus, potassium, calcium, magnesium, sulfur, and essential
micronutrients, contributing to plant growth, metabolic activity, and crop development. The
formulation also contains amino acids and functional additives, which support nutrient absorption and
plant physiological processes. The product is intended exclusively for agricultural plant nutrition
purposes and does not contain pesticidal active ingredients or pesticidal claims. The provided photo of
the packaging indicates that Mega will be imported in one-liter plastic containers.
Recommended Use: Foliar fertilizer for agricultural crops.
Composition Guaranteed Analysis: 5.0% Nitrogen (N), 8.0% Phosphorus (PO), 8.0% Potassium
(KO), 1.0% Calcium (Ca), 1.0% Magnesium (Mg), 2.17% Sulfur (S), and micronutrients.
Additional Additives: Amino acids, Thickening agents, Antifreeze agents, Anti-evaporation agents.
Physical and Chemical Properties: Appearance: Brown liquid, Odor: Characteristic, pH: < 3.0,
Density: 1.41 g/mL, Soluble in water.
In your submission you suggest classification as follows: Aminomix 3105.20.20, Harmonized Tariff
Schedule of the United States (HTSUS), Biofran 3105.20.00, HTSUS, Max Fulvic 3101.00.00, HTSUS, and
Mega 3105.20.00, HTSUS. Upon review, we have found your suggested classifications to be incorrect, as
the subject products are provided for elsewhere in the HTSUS.
The applicable subheading for Aminomix, Biofran, Max Fulvic, and Mega fertilizers will be 3105.10.0000,
HTSUS, which provides for Mineral or chemical fertilizers containing two or three of the fertilizing elements
nitrogen, phosphorus and potassium; other fertilizers; goods of this chapter in tablets or similar forms or in
packages of a gross weight not exceeding 10 kg: Products of this chapter in tablets or similar forms or in
packages of a gross weight not exceeding 10 kg. The general rate of duty will be free.
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 merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which
are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by
contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone
at (202) 554-1404, or by visiting their website at www.epa.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 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)
James P. Forkan
Director
National Commodity Specialist Division