The tariff classification of a mould release agent from Germany

N353373 October 3, 2025 CLA-2-21:OT:RR:NC:N5:228 CATEGORY: Classification TARIFF NO.: 2106.90.9998; 9903.02.20 Lawrence Millington Freudenberg North America 47774 W. Anchor Court Plymouth, MI 48170 RE: The tariff classification of a mould release agent from Germany Dear Mr. Millington: In your letter dated September 5, 2025, you requested a tariff classification ruling on behalf of your client, Capol, LLC. An ingredients breakdown and a product specification sheet accompanied your inquiry. The product, “Capolex 710,” is said to be a food grade mould release agent that has an appearance of a yellowish oily dispersion of typical odor. The product is composed of vegetable oil, carnauba wax and acetic acid esters of mono and diglycerides of fatty acids and will be packaged in 10 kg., 50 kg., or 100 kg. plastic airtight containers made of high-density polyethylene for sale to customers. The applicable subheading for the product, “Capolex 710,” will be 2106.90.9998, Harmonized Tariff Schedule of the United States (HTSUS), which provides for food preparations not elsewhere specified or included . . . other . . . other . . . other. The general rate of duty will be 6.4 percent ad valorem. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 2106.90.9998, HTSUS, listed above. The tariffs and additional 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 merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling FDA at 301-575-0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html. 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 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 Timothy Petrulonis at Timothy.Petrulonis@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division