N359569

N359569 April 1, 2026 CLA-2-38:OT:RR:NC:N3:139 CATEGORY: Classification, Trade Programs, Country of Origin, TARIFF NO.: 3824.99.4190 Scott Dyke SS Ventures Incorporated SW 27-14-18 W, PO Box 1421 Minnedosa R0J 1E0 Canada RE: The tariff classification, country of origin, and eligibility of the United States-Mexico-Canada Agreement (USMCA) of various waxes used in the playing of ice hockey, from Canada Dear Mr. Dyke: In your letter dated March 9, 2026, and an earlier submission, you requested a binding ruling on the tariff classification, country of origin, and eligibility of various waxes used in the playing of ice hockey under the United States-Mexico-Canada Agreement (USMCA). You state that the waxes under under review are applied to hockey sticks, and goalie pads. The products that you are importing into the United States are as follows: a. Sniper Sauce Premium Natural Hockey Wax — Black Cherry. b. Sniper Sauce Premium Natural Hockey Wax — Blue Raspberry. c. Sniper Sauce Premium Natural Hockey Wax — Classy Sasquatch. d. Sniper Sauce Premium Natural Hockey Wax — Cotton Candy. e. Sniper Sauce Premium Natural Hockey Wax — Island Coconut. f. Sniper Sauce Premium Natural Hockey Wax — Juicy Fruit. g. Sniper Sauce Premium Natural Hockey Wax — Monkey Farts. h. Sniper Sauce Slider Sauce Goalie Pad Wax. All of the items are various combinations of beeswax granules (country of origin Canada), hydrogenated soybean wax flakes (country of origin United States), and either fragrance oil (country of origin Canada) or food grade white mineral oil (country of origin United States). You state that to make these ice hockey waxes, the beeswax granules and the soybean wax flakes are measured out to certain proportions and then placed into a commercial wax melter until they are fully melted into a liquid state. Once this is accomplished, the liquid wax is placed into a mixing pot where either the fragrance oil or the mineral oil is added and stirred for two minutes. The mixture is then poured into silicone molds and then left to cool and harden into a solid state. Once this is accomplished, the solidified wax is placed into their labeled aluminum tins for sale to their final purchaser. Classification: In your earlier submission you suggested classification for the various ice hockey waxes in subheading 9506.99.2580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Ice-hockey and field-hockey articles and equipment, …: Other, including parts and accessories." We disagree. The instant product, a hydrophobic wax, is not akin to hockey equipment, parts or accessories, but rather is more specifically provided for elsewhere in the tariff. The applicable subheading for the various ice hockey waxes will be subheading 3824.99.4190 HTSUS, which provides for “Fatty substances of animal or vegetable origin and mixtures: Other”. The rate of duty will be 4.6 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. USMCA: The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a "good originating in the territory of a USMCA country" only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since all of the ingredients in the various ice hockey waxes are USMCA originating, the product are goods produced entirely in the territory of one or more USMCA countries, exclusively from originating materials under GN 11(b)(ii). Therefore, the various ice hockey waxes, would be eligible for preferential tariff treatment under the USMCA. The goods will therefore be entitled to a free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and agreements. Country of origin: Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, the hierarchy provides that the country of origi

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, CBP 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 CBP Regulations (19 CFR. 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 John Bobel at john.bobel@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division