RE: The tariff classification of KP-Topcoat from Belgium

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 N365274 October 13, 2026 CLA-2-32:OT:RR:NC:N3:136 CATEGORY: Classification TARIFF NO.: 3210.00.0000 Fanny Hjartardottir Kalklitir BV Rozenberg 62 Mol 2400 Belgium RE: The tariff classification of KP-Topcoat from Belgium Dear Ms. Hjartardottir: In your letter dated September 22, 2026, you requested a tariff classification ruling on KP-Topcoat. In your submission you state that KP-Topcoat, also identified as Kalklitir Top Coat, is a mineral-based protective coating supplied in dry powder form. The product is intended for use as a finishing and protective coating over decorative wall finishes. It is mixed with water prior to application and applied in a thin layer to the finished wall surface. The product is supplied as a white, odorless solid powder and is soluble in water. Once mixed with water, it forms a water-based coating intended to provide additional surface protection while maintaining a matte appearance. The product is classified by the manufacturer as a paint/coating and is suitable for consumer, professional, and industrial use. The Safety Data Sheet identifies the product as a mixture and states that it does not contain substances that are required to be individually declared under the criteria of Section 3.2 of REACH Annex II. KP Topcoat is non-flammable and is not classified as hazardous under the applicable European CLP classification. The finished product is manufactured and packaged in Belgium by Kalklitir BV and will be exported from Belgium to the United States. The applicable subheading for the KP-Topcoat will be 3210.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other paints and varnishes (including enamels, lacquers and distempers); prepared water pigments of a kind used for finishing leather. The general rate of duty will be 1.8 percent ad valorum. On the completed Submission Summary, you also indicate that you are requesting a country of origin determination. Since you do not describe a scenario where the country of origin is in question and you state that the subject product is manufactured and packaged in Belgium, the country of origin for duty and marking purposes is Belgium. 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 Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division