CLA-2-32:OT:RR:NC:N3:136
Fanny Hjartardottir
Kalklitir BV
Rozenberg 62
Mol 2400
Belgium
RE: The tariff classification and country of origin of Lime Wash Paint from Belgium.
Dear Ms. Hjartardottir:
In your letter dated April 7, 2026, you requested a tariff classification and country of origin determination
ruling on Lime Wash Paint.
In your submission, the subject product is described as a natural mineral-based lime wash paint,
manufactured in Belgium by Kalklitir BV. The product is a decorative surface coating, available in 36 color
variations, used for interior and exterior wall applications. It is supplied in powder form and mixed with
water prior to application. The paint is typically applied in two coats using a brush to create a matte, textured
finish. The composition of the product consists primarily of slaked lime (calcium hydroxide), mineral
pigments, and small amounts of natural additives. The product is water-based once mixed and does not
contain synthetic resins or acrylic binders. The principal use of the Lime Wash Paint is as a decorative and
protective wall finish for residential and commercial surfaces, including plaster, drywall, brick, and masonry.
You state that this product is manufactured entirely in Belgium. All blending, processing, and packaging
take place at your facility in Mol, Belgium. The finished product will be exported from Belgium to the
United States.
The applicable subheading for the Lime Wash Paint will be 3210.00.0000, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for: Other paints and varnishes (including enamels, lacquers and
distempers); prepared water pigments of a kind used for finishing leather. The general rate of duty will be
1.8 percent ad valorem.
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 (EPA). Information on the TSCA can be
obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and
Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C.,
20460, by calling the Toxic Substances Control Act Hotline at 800-471-7127, by e-mailing to
[email protected], or by visiting their website at www.epa.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.
Country of Origin
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc.
v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence.
See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Regarding the country of origin of the Lime Wash Paint. You state that this product is manufactured entirely
in Belgium; all blending, processing, and packaging will take place at your facility in Mol, Belgium.
Therefore, it is the opinion of this office that the country of origin of the Lime Wash Paint is Belgium.
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