RE: The tariff classification of insecticidal agricultural netting from Vietnam

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 N364754 September 29, 2026 CLA-2-60:OT:RR:NC:N2:352 CATEGORY: Classification TARIFF NO.: 6005.37.0010 Tracey Baughman Hellmann Worldwide Logistics 10450 Doral Blvd. Miami, FL 48111 RE: The tariff classification of insecticidal agricultural netting from Vietnam Dear Ms. Baughman: In your letter dated September 1, 2026, you requested a tariff classification ruling on behalf of your client, Vestergaard Frandsen Inc., for an insecticidal agricultural netting. Sample pieces of the netting were submitted with your request and will be retained for training purposes. The netting, identified as “PermaNet Screen® Insecticidal Agricultural Netting,” is designed to be used as a long-lasting insecticide-incorporated netting (LLIN) for agricultural applications, including structural screens, crop protection, plant wraps and livestock pest management. The netting is an open-work, warp knit fabric composed wholly of polyethylene; it is dyed and weighs 55 grams per square meter (g/m2). Additionally, the netting features double-knit side borders and unhemmed, straight blade-cut edges at the top and bottom. The fabric is unknotted and treated with the active insecticide deltamethrin. Based on the information provided, the netting will be imported in rolls and will be available in the following eight sizes and weights: 30 x 3 feet (1 lbs./0.46kgs), 30 x 4 feet (1.34 lbs./0.61 kg), 100 x 3 feet (3.37 lbs./1.53 kg), 100 x 4 feet (4.5 lbs./2.04 kg), 100 x 5 feet (5.64 lbs./2.56 kg), 300 x 5 feet (16.91 lbs./7.67 kg), 100 x 8 feet (9.02 lbs./4.09 kg) and 300 x 8 feet (27.05 lbs./12.27 kg). The insecticidal agricultural netting is a composite good consisting of the active insecticide deltamethrin (heading 3808) applied to an open-work, warp-knit fabric (heading 6005). Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS), is in accordance with the General Rules of Interpretation (GRIs). GRI 1 states, in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes, and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings refer to part only of the items in a composite good, those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the good. As such, they are regarded as equally specific, and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI 3(b) states, in part, that composite goods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. In this case, both the insecticidal component (heading 3808) and the knitted netting fabric (heading 6005) are equally essential to the product's function. The item cannot serve its intended agricultural purpose without both its chemical protection and its physical barrier. Consequently, the essential character of the overall product cannot be ascribed to either single component. In your letter, you suggest classification of the “PermaNet Screen® Insecticidal Agricultural Netting” under subheading 3808.91.2501, HTSUS, which provides for: “Insecticides, rodenticides, fungicides, herbicides, … and similar products, put up in forms or packings for retail sale or as preparations or articles (for example, sulfur-treated bands, wicks and candles, and flypapers): Other: Insecticides: Other: Containing any aromatic or modified aromatic insecticide: Other.” We disagree. According to GRI 3, if goods are prima facie classifiable under two or more headings, the rules must be applied sequentially. Here, the “PermaNet Screen® Insecticidal Agricultural Netting” cannot be classified under GRI 3(a) or GRI 3(b), so classification is determined under GRI 3(c). Pursuant to GRI 3(c) directs that in such circumstances the classification will be the heading that appears last in numerical order among those which equally merit consideration. Since heading 6005 occurs last between the competing headings (3808 and 6005), the “PermaNet Screen® Insecticidal Agricultural Netting” is properly classified under heading 6005, HTSUS. The applicable subheading for “PermaNet Screen® Insecticidal Agricultural Netting,” will be 6005.37.0010, HTSUS, which provides for “Warp knit fabrics (including those made on galloon knitting machines), other than those of headings 6001 to 6004: (con.): Of synthetic fibers: Other: Other, dyed: Open-work fabrics.” The general rate of duty will be 10 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 Nicole Rosso at nicole.rosso@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division