The tariff classification of a food industry emulsifier from India

N357024 July 8, 2026 CLA-2-38:OT:RR:NC:N3:139 CATEGORY: Classification TARIFF NO.: 3824.99.4190 Jose Maldonado Nirav Ingredients 11405 North Community House Road Suite 290 Charlotte, NC 28277 RE: The tariff classification of a food industry emulsifier from India Dear Mr. Maldonado: In your letter dated December 15, 2025, and earlier submissions, you requested a tariff classification ruling. A sample was submitted and will be retained for reference purposes. The instant item is described as a food industry emulsifier with the product name of Finamul 6016. Your state Finamul 6016 would be used in conjunction with bakery, non-dairy creamer, and coffee creamer products. CBP Laboratory analysis found that it consisted of sodium stearate, sodium stearoyl mono-lactylate, and sodium stearoyl di-lactylate. You suggest classification in subheading 2918.11.5100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Carboxylic acids with alcohol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Lactic acid, its salts and esters: Other.” We disagree. Based upon our lab’s review, the sample provided is not a separate chemically defined organic compound as defined in Chapter 29, Note 1. The product is a mixture of compounds in their salt form and is therefore excluded from Chapter 29. The applicable subheading for Finamul 6016 will be 3824.99.4190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Fatty substances of animal or vegetable origin and mixtures thereof: Other. The general rate of duty will be 4.6 percent ad valorem. The 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 ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 John Bobel at john.bobel@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division