CLA-1-34:OT:RR:NC:N3:136
Eric Peterson
The Swatch Group U.S. Inc.
1200 Harbor Blvd.
Weehawken, NJ 07086
RE: The tariff classification of “Rodico” from Malaysia
Dear Mr. Peterson:
In your ruling request dated August 4, 2020, you requested a tariff classification ruling on “Rodico.”
The subject product is described as a cleaning compound in the form of putty. You state that the most common uses for “Rodico” are to remove oil and fingerprints from watch parts, clean movement plates, bridges, dials, balance pivots, train wheel pivots, and gears. “Rodico” removes oil, crud, dust, and debris from tools and removes dirt and oils from jewelry. This product also helps pick up and maneuver small watch parts like jewels and screws, removes broken-off pieces of pegwood, holds or positions a watch part or tool at your workbench and may be used to grip and open a case back without marring the case. We have determined that the subject product is a cleaning preparation, not having a basis of soap or other organic surface-active agents.
In your request, you suggest classification in subheading 3407.00.4000, Harmonized Tariff Schedule of the United States (HTSUS); however, we have found that to be incorrect, because the subject product is more specifically provided for elseware in the tariff schedule.
The applicable subheading for “Rodico” will be 3402.90.5030, HTSUS, which provides for Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Other: Other: Other: Cleaning preparations. The general rate of duty will be 3.7 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. 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.
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 on World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Nuccio Fera at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division