CLA-2-38:OT:RR:NC:N3 135
Stephanie Rodriguez
CAPEZIO
1 Campus Road, Totowa, NJ 07512
RE: The tariff classification of pine rosin from China
Dear Ms. Rodriguez:
In your letter dated September 23, 2024, you requested a tariff classification ruling. Additional information was provided by email, dated September 25, 2024. A sample was received, examined, and disposed of.
Bunheads Rock Rosin is 100 percent pine rosin in the form of blocks or chunks packed in a plastic jar containing 10 oz., net weight. The manufacturing process of the pine rosin involves the following steps: (1) collection of oleoresin; (2) drying (this process can be accelerated by heating, which helps to evaporate the volatile oils.); (3) distillation to remove the volatile oils; (4) filtration; (5) hardening; (6) cooling and solidification (in this step, rosin can then be formed into blocks or chunks, which are the typical form of rock rosin.); and (7) grinding (if needed).
The applicable subheading for the Rock Rosin will be 3806.10.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for [r]osin and resin acids, and derivatives thereof : [r]osin and resin acids: [o]ther. The rate of duty will be 5 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3806.10.0050, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 3806.10.0050, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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/.
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 Fei Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division