The tariff classification of disposable polypropylene containers and lids from China

N354857 October 27, 2025 CLA-2-39:OT:RR:NC:N5:137 CATEGORY: Classification TARIFF NO.: 3923.90.0080, 3923.50.0000, 9903.01.24, 9903.01.25, 9903.88.03 Jerry Robbins Applicator International, LLC 7880 West Sacramento Hill Dr, Tucson, AZ 85743 RE: The tariff classification of disposable polypropylene containers and lids from China Dear Mr. Robbins: In your letter dated October 10, 2025, you requested a tariff classification ruling. Item 1 consists of polypropylene lids that are used to seal plastic containers. Photos of the lids were provided with the request. They are imported in 4-inch, 6-inch, and 8-inch sizes. The lids are of the kind to be used on containers to carry take-out servings of food from supermarkets, delis, etc. Item 2 consists of the polypropylene containers. Photos of the containers were provided with your request. The containers are of a kind used to carry take-out servings of food from supermarkets, delis, etc. You do not indicate whether the lids and containers will be imported together or separately. The applicable subheading for the polypropylene containers imported with or without lids will be 3923.90.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics: other: other. The general rate of duty will be 3 percent ad valorem. The applicable subheading for the polypropylene lids imported separately from containers will be 3923.50.0000, HTSUS, which provides for articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics: stoppers, lids, caps and other closures. The general rate of duty will be 5.3 percent ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 3923.90.0080 or 3923.50.0000, HTSUS, listed above. 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 China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 3923.90.0080 or 3923.50.0000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3923.90.0080 or 3923.50.0000, 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 3923.90.0080 or 3923.50.0000, 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/programs-administration/trade-remedies, respectively. 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/. 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 Christina Allen at julie.c.allen@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division