RE: The tariff classification of Frozen Roasted Garlic Cloves from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364401 September 15, 2026 CLA-2-20:OT:RR:NC:N5:228 CATEGORY: Classification TARIFF NO.: 2004.90.8565 Ms. Kayla Owens Stein Shostak Shostak Pollack & O'Hara, LLP 445 South Figueroa Street, Suite 2388 Los Angeles, CA 90071 RE: The tariff classification of Frozen Roasted Garlic Cloves from China Dear Ms. Owens: In your letter dated August 19, 2026, you requested a tariff classification ruling on behalf of your client, Shandong Xingda Foodstuffs Group Co. (Shandong, China). A description of the manufacturing process, plus a manufacturing flowchart and product photograph, accompanied your letter. The product, Frozen Roasted Garlic Cloves, is described as fresh garlic cloves that contain no additives, sugar, water, or preservatives. The cloves undergo a multi-step manufacturing process in which the fresh garlic experiences a Maillard browning reaction. The product will be imported frozen, in bulk quantities of 10 kilograms per carton, from garlic sauce manufacturing plants, and is intended for sale to the garlic sauce seasoning sector. A photograph of the product depicts the garlic cloves with a warm color gradient ranging from light honey gold to rich deep amber brown. The frozen roasted garlic cloves are said to be manufactured by first peeling and then removing the stems of raw garlic cloves. Next the cloves are cleaned with water, drained, roasted, and baked at proprietary temperature levels and durations, subsequent to being frozen at temperatures of approximately negative eighteen degrees Celsius, for importation. The oven used to manufacture the cloves is of food grade 304 stainless steel and described as having three layers, each nine meters long. Hot air enters from the bottom and exits through the top. Fresh garlic cloves are fed into the first top layer and discharged from the third layer. Roasting takes place in the first layer, while baking occurs in the second and third. The Maillard browning reaction is said to occur during the high-temperature baking process when the garlic cloves develop a crispy surface texture and golden yellow color. The applicable subheading for the Frozen Roasted Garlic Cloves will be 2004.90.8565, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “Other vegetables prepared or preserved otherwise than by vinegar or acetic acid, frozen, other than products of heading 2006: Other vegetables and mixtures of vegetables: Other: Garlic: Peeled clove garlic, whether or not individually quick frozen.” The general rate of duty will be 11.2 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 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 Timothy Petrulonis at timothy.petrulonis@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division