The following proposed revocations of U.S. Customs and Border Protection classification rulings are included in the Dec. 29, 2021, Customs Bulletin and Decisions. Comments on these proposed changes are due by Jan. 28.

For more information on how to seek or utilize classification and other rulings, please contact attorney Deb Stern at (305) 894-1007 or via email.

Flea Drops

CBP is proposing to reclassify flea drops as insecticides under HTSUS 3808.91.50 (6.5 percent duty) rather than as veterinary drugs under HTSUS 3004.90.9003 (duty-free). Rulings NY F86615 and NY A84405 would be revoked to reflect this change.

The subject goods consist of six plastic snap-open tubes put up for retail sale in a paperboard container. Each tube contains a formulated insecticide indicated for topical application on dogs and cats to kill fleas. The two active ingredients are sodium lauryl sulfate (seven percent) and citric acid (five percent), both of which are considered pesticides by the Environmental Protection Agency. The inert ingredients are hydrogenated vegetable oil, soybean oil, and glycerin.

CBP explains that the flea drops are not a treatment for a disease or an affliction because they do not have an effect on the pet’s body. Instead, they attract and interfere with the life cycles of the infesting pests.


CBP is proposing to reclassify steel T-sections as steel angles, shapes, and sections under HTSUS 7216.50.00 rather than as elevator parts under HTSUS 8431.31.00. Under the proposed classification the T-sections would be subject to existing Section 232 tariffs on steel products. Rulings HQ 965520 and NY 898929  would be revoked to reflect this change.

The subject goods are T-shaped sections of hot-rolled, non-alloy steel that are used to guide elevator cars as they travel up and down an elevator shaft. CBP states that as imported these items will need to undergo a total fabrication before they will be ready for assembly in the elevator shaft and recognizable as a finished part.

Pet Bowls

CBP is proposing to reclassify certain pet bowls as plastic household articles under HTSUS 3924.90.56 (3.4 percent duty) rather than as other articles of wood under HTSUS 4421.91.9780 (3.3 percent duty). Ruling NY N305668 would be revoked to reflect this change.

The subject pet bowls are made of 57 percent bamboo fiber powder, 10 percent melamine, 20 percent corn starch, 2 percent dry powder colorant, and 11 percent glue. CBP states that the bamboo fiber powder becomes plastic in the molding of the bowls.

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