CLA-2-21:S:N:N1:228

Ms. Lourdes Martelly
J.P. Reynolds Company, Inc.
P.O. Box 13071
Fort Lauderdale, FL 33316

RE: The tariff classification of cheese spreads from Venezuela

Dear Ms. Martelly:

In your letters dated May 16, 1991 and December 11, 1991, on behalf of Venezuelan Shoe Industries Corp., Fort Lauderdale, FL, you requested a tariff classification ruling.

Samples, an ingredients breakdown, and a description of the manufacturing process accompanied your letters. "Rikesa" brand cheese spread is a homogenous, golden-yellow product, with a soft, creamy, consistency, put up in glass jars holding 200 or 300 grams, net weight. The spreads - "regular" and bacon- flavored variety - are said to consist of water, hydrogenated vegetable oil, powdered skim milk, cheddar cheese, disodium phosphate, salt, cheese extract, Worcestershire sauce, mustard extract, potassium sorbate, paprika, and vitamins A and B2. The bacon-flavored variety also contains bacon flavor.

The applicable subheading for the cheese spreads will be 2106.90.6099, Harmonized Tariff Schedule of the United States (HTS), which provides for food preparations not elsewhere specified or included...other... other...other. The duty rate will be 10 percent ad valorem.

Articles classifiable under subheading 2106.90.6099, HTS, which are products of Venezuela are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

The submitted photocopies of the "suggested labels" appear to be properly marked with the country of origin, as required by Section 134 of the Customs Regulations (19 C.F.R. 134). If the labels are modified in any way, it is suggested you discuss the matter with the import specialist at the proposed port of entry.

The samples are returned to you, as requested.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport