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 Max Fulvic 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 Max Fulvic.
In your submission, the subject product is identified as Max Fulvic. You state that Max Fulvic is an
organomineral fertilizer formulated to supply nitrogen, potassium, sulfur, and organic carbon for plant
nutrition. This 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. This 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 Aminomix will be imported in one-liter plastic containers.
Recommended Use: Foliar fertilizer, soil application, and fertigation.
Composition Guaranteed Analysis: 10.0% Nitrogen (N), 5.0% Potassium (KO), 1.5% Sulfur (S), 20.0%
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, Odor: Characteristic, pH: > 7, Density: 1.33
g/mL, Soluble in water.
In your submission you suggest classification in subheading 3101.00.00, Harmonized Tariff Schedule of the
United States (HTSUS). Upon review, we have found your suggested classification to be incorrect, as the
subject product is provided for elseware in the HTSUS.
The applicable subheading for Max Fulvic 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