The tariff classification of coconut cream and coconut milk from Thailand

N359241 March 23, 2026 CLA-2-21:OT:RR:NC:N5:229 CATEGORY: Classification TARIFF NO.: 2106.90.9980 Erik D. Smithweiss GDLSK LLP 707 Wilshire Boulevard Los Angeles, CA 90017 RE: The tariff classification of coconut cream and coconut milk from Thailand Dear Mr. Smithweiss: In your letter dated February 26, 2026, you requested a tariff classification ruling on behalf of your client, Linbro, Inc. An ingredients breakdown, a description of the manufacturing process and product specification sheets of five products accompanied your inquiry. The subject merchandise is described as coconut cream and coconut milk. The coconut cream will be used as an ingredient in various foods and beverages while the coconut milk may be used as an ingredient or as a replacement for dairy milk in smoothies, teas, and other applications. The first product, “Organic Coconut Cream (22-24% Fat),” is said to contain approximately 70 percent organic coconut extract, 29.78 percent water, 0.2 percent xanthan gum (E415), and 0.2 percent organic guar gum (E412). The second product, “Coconut Cream (22-24% Fat),” is said to contain approximately 80 percent coconut extract, 19.38 percent water, 0.21 percent guar gum (E412), 0.21 percent sodium carboxy methyl cellulose (E466), and 0.2 percent polysorbate 60 (E435). The third product, “Coconut Cream (21-22% Fat),” is said to contain approximately 78 percent coconut extract, 21.68 percent water and 0.32 percent guar gum (E412). The fourth product, “Light Coconut Milk (5-7% Fat),” is said to contain approximately 40 percent coconut extract, 59.3 percent water and 0.7 percent guar gum (E412). The fifth product, “Coconut Milk (17-18% Fat),” is said to contain approximately 75 percent organic coconut extract, 24.7 percent water and 0.3 percent organic guar gum (E412). The coconut milk is described as a liquid prepared by extracting selected coconut meat, washing, blanching, grating, squeezing, vibration filtration, and preheating. Once filtered, the stabilizing additives are mixed with the coconut liquid, which is then preheated and filtered again to remove any additional foreign material. The liquid then goes through a homogenization and UHT sterilization process, after which it is placed in an aseptic tank, packaged, and prepared for transport. The coconut cream is prepared similarly but contains a higher fat content. In your letter, you proposed classification for the products under subheading 2008.19.1500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for fruit, nuts and other edible parts of plants, otherwise prepared or preserved, whether or not containing added sugar or other sweetening matter or spirit, not elsewhere specified or included … nuts, peanuts (ground-nuts) and other seeds, whether or not mixed together … other, including mixtures … coconuts. Based on the ingredients breakdown and manufacturing narrative provided, the products will be classified elsewhere. The applicable subheading for the five products, “Organic Coconut Cream (22-24% Fat),” “Coconut Cream (22-24% Fat),” “Coconut Cream (21-22% Fat),” “Light Coconut Milk (5-7% Fat),” and “Coconut Milk (17-18% Fat),” will be 2106.90.9980, HTSUS, which provides for Food preparations not elsewhere specified or included: Other: Other: Other: Other: Other: Other: Other cream or milk substitutes. The general rate of duty will be 6.4 percent. 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 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. 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 Christopher Gangaprashad at christopher.gangaprashad@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division