The tariff classification of dosimeter pellets from France

N352501
January 29, 2026
CLA-2-38:OT:RR:NC:N3 139
CATEGORY: Classification
TARIFF NO.: 3824.99.9397
Deniz Gunes GEX Corporation 4437 SW Cargo Way , Palm City, FL 34990 RE: The tariff classification of dosimeter pellets from France Dear Mr. Gunes: In your letter dated August 15, 2025, you requested a tariff classification ruling. The item under review is a pellet that is said to be a combination of an L-enantiomer of the amino acid alanine, an ethyl acrylate and methyl methacrylate copolymer in a aqueous dispersion, and an emulsifier consisting of: distilled propylene glycol monoester (E477), mono- and diglycerides (E471), and sodium stearoyl lactylate. You state that your company provides your customers with certified and traceable high dose radiation measurements using these pellet dosimeters. Your customers use your transfer-standard dosimeter service to calibrate their dosimetry systems by irradiation of your dosimeter products at their irradiation facility alongside their dosimeters. You state that your certified dose measurements are also useful for establishing dose rate(s) for, or mapping of, radiation fields produced by gamma ray, X-ray or electron beam sources. Based on what you have submitted, it appears that the pellets would be imported into the United States from France in bulk or individually in a blister pack. You state also that subsequent to their importation, some of the pellets may be assembled into disk or vial holders at your facility in Palm City, Florida. The applicable subheading for the dosimeter pellets will be 3824.99.9397, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other: Other: Other: Other. The general rate of duty will be 5 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 Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 John Bobel at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division