The tariff classification of a concrete flooring base and hardener from South Korea

N352957
September 10, 2025
CLA-2-38:OT:RR:NC:N3:139
CATEGORY: Classification
TARIFF NO.: 3824.99.2900; 9903.01.32
Jiwon Kwon Cusan Customs Service Incorporated #309, 35, Magokjungang 2-ro, Gangseo-gu, Seoul 07806 Republic of Korea RE: The tariff classification of a concrete flooring base and hardener from South Korea Dear Jiwon Kwon: In your letter filed on behalf of your client Noroo Paint & Coatings Company, Limited dated August 27, 2025, you requested a tariff classification ruling. There are two products under review which both have a product name of YEGREENA CRYSTAL. One is a base and the other is a hardener. Subsequent to importation, the base and the hardener are mixed together and applied to a concrete floor in a residential or commercial building. Once applied, it provides a protective and decorative surface coating to the flooring and resistance to chemicals, and abrasion. The base is said to consist of a diglycidyl ether, a phenol, a alcohol, and a naptha solvent. The hardener is said to consist of a diol, a alcohol, a cycloaliphatic amine, a tall oil fatty acid, a different substance you asked us not to identify, and two different types of phenols. In your submission you suggest classification of the base and hardener under subheading 3824.99.2900 Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the base, and the hardener will be 3824.99.2900 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: Mixtures containing 5 percent or more by weight of one or more aromatic or modified aromatic substances: Other. The general rate of duty will be 6.5 percent ad valorem. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of South Korea will be subject to an additional ad valorem rate of duty of 15 percent. Your product falls within an excepted

subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 3824.99.2900, HTSUS, listed above. The tariffs and additional 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/. 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 Acting Director National Commodity Specialist Division