Dec. 29 CBP Bulletin Proposes to Revoke Rulings on Flea Drops, Pet Bowls
In the Dec.29 Customs Bulletin (Vol. 55, No. 51), CBP published a proposal to revoke rulings on flea drops and pet bowls.
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Comments on Proposals Due Jan. 28
CBP said consideration will be given to any written comments received by Jan. 28 before taking these actions. In addition, any party that has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Flea Drops
| Item: Insecticide used to kill fleas on dogs and cats |
| Current: 3004.90.9003, Free, "[M]edicaments ... consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses or in forms or packings for retail sale: Other: Other: For veterinary use." |
| Proposed: 3808.91.2501, 6.5%, “Insecticides, rodenticides, fungicides ...put up in forms or packings for retail sale or as preparations ...: Other: Insecticides: Other: Other..." |
| Reason: As the flea drops kill fleas and ticks but do not prevent or treat any disease or affliction of the pet’s body, they cannot be classified as medicaments of heading 3004. |
| Proposed for revocation: NY F86615, dated May 24, 2000, and NY A84405, dated June 17, 1996 |
| Proposed new ruling: HQ H232357 |
Pet Bowls
| Item: Plastic pet bowls |
| Current: 4421.91.9780, 3.3%, "Other articles of wood: Of bamboo: Other: Other: Other: Other." |
| Proposed: 3924.90.56, 3.4%, “Household articles of plastics." |
| Reason: The pet bowls are made predominantly of bamboo fiber powder that becomes plastic in the molding. |
| Proposed for revocation: NY N305668, dated Aug. 14, 2019 |
| Proposed new ruling: HQ H306852 |