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RE: The tariff classification of plastic jugs from Canada
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 N365191 September 24, 2026 CLA-2-39:OT:RR:NC:N5: 463 CATEGORY: Classification TARIFF NO.: 3923.30.0090 Vicente Memoli Sonny's Enterprise LLC 5870 N Hiatus Rd. Tamarac, FL 33321 RE: The tariff classification of plastic jugs from Canada Dear Mr. Memoli: In your letter dated September 17, 2026, you requested a tariff classification ruling for plastic jugs. The subject merchandise is described as empty 2.5-gallon plastic jugs composed of high density polyethylene (HDPE). It will be imported with plastic screw caps and dispensing closures composed of polypropylene (PP). It measures approximately 14.35 inches tall and has an opening at the top that measures 2.50 inches. You indicate that the plastic jugs will be filled with liquid carwash chemicals, including detergents, presoaks, protectants, waxes, tire dressings, and similar automotive care products upon importation. The final products are marketed and sold throughout the professional carwash industry. You also state that the plastic jugs are not designed for repeated use. In your request, you state that plastic jugs would be classified under subheading 3923.30.0010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles for the conveyance or packing of goods, of plastics: carboys, bottles, flasks and similar articles: of a capacity not exceeding 50 ml. We disagree. The capacity of plastic jars is 2.5 gallons (9464 ml) which exceeds 50 ml. Therefore, the plastic jugs are excluded from classification in 3923.30.0010, HTSUS. The applicable subheading for the plastic jugs will be 3923.30.0090, HTSUS, which provides for articles for articles for the conveyance or packing of goods, of plastics: carboys, bottles, flasks and similar articles: other. The general rate of duty will be 3 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 ChingJu (Claudia) Lin at chingju.lin@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division
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 ChingJu (Claudia) Lin at chingju.lin@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division