HQ 088315

April 30,1991

CLA-2 CO:R:C:F 088315 SLR

District Director of Customs
335 Merchant 228 Customhouse
Honolulu, HI 96813

RE: Protest No. 3201-0-000002 Dried Seaweed Further Processed

Dear Sir:

This is our decision regarding Application for Further Review of Protest No. 3201-0-000002, filed January 11, 1990, against your decision in the classification of dried seaweed entered on May 16, 1989, and liquidated on October 13, 1989.

FACTS:

The merchandise at issue consists of seaweed which has been cut, made into a paste, flattened to a sheet, dried naturally, then roasted.

You liquidated the subject merchandise in subheading 2008.99.90, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for fruit, nuts, and other edible parts of plants, otherwise prepared or preserved, not elsewhere specified or included.

The protestant maintains that the seaweed is classifiable in subheading 1212.20.00, HTSUSA, which provides for seaweeds and other algae.

ISSUE:

Whether Chapter 12, HTSUSA, "seaweed" includes all forms of seaweed or just crude seaweed.

LAW AND ANALYSIS:

Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification is determined according to the terms of the headings and any relative section or chapter notes. -2-

Heading 1212, HTSUSA, provides for, among other products, seaweed. Explanatory Note (B) to heading 1212, HTSUSA, indicates that this heading covers: [A]ll seaweeds and other algae, whether or not edible. They may be fresh, dried or ground. * * *

The seaweed of heading 1212 is limited to seaweed prepared no further than drying or reduction in size. Cooking, roasting, or the addition of other ingredients result in food preparations based on seaweed. Accordingly, the seaweed in question is more appropriately classifiable in heading 2008, HTSUSA, which provides for fruits, nuts and other edible parts of plants, otherwise prepared or preserved, not elsewhere specified or included.

This classification is in conformity with the basic structure of the tariff schedule. Generally speaking, HTSUSA chapters based on material are organized to reflect the various levels of processing. Chapter 12 includes crude or unmanufactured products. Chapters 20 and 21 include Chapter 12 products further prepared for human consumption.

HOLDING:

The dried seaweed is classifiable in subheading 2008.99.9090, HTSUSA, which provides for fruits, nuts and other edible parts of plants, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included: other, including mixtures other than those of subheading 2008.19, other, other, other, other. The applicable rate of duty is 7 percent ad valorem.

You are to deny the protest in full. A copy of this decision should be sent to the protestant along with the Form 19 Notice of Action.


Sincerely,

John Durant, Director
Commercial Rulings Division