N356420
December 15, 2025
CLA-2-21:OT:RR:NC:N5:228
CATEGORY: Classification
TARIFF NO.: 2106.90.9995
Dhruv Dhawan Nadura Foods LLC 8 The Green, Suite R Dover, DE 19901 The tariff classification of an edible preparation from the United Arab Emirates Dear Dhruv Dhawan: In your letter dated November 25, 2025, you requested a tariff classification ruling. In lieu of samples, an ingredients breakdown, manufacturing flowchart, and product specification sheets were provided. The subject merchandise is described as five varieties of pea-protein based meat substitute products to be imported from the United Arab Emirates. The products are said to be formulated food preparations composed primarily of textured pea protein, vegetable oils, seasonings, and natural flavors. The products are produced in mince, patties, and kebabs. At the time of U.S. importation, the subject merchandise is imported frozen in “foodservice-size packaging.” Item 1, “Pea Protein Mince Beef-Style,” is composed of 57 percent water, 28 percent pea protein, 2 percent sunflower oil, 2.5 percent shea oil, 2.5 percent coconut oil, less than 2 percent onion powder and garlic powder, and less than 5 percent spices, rice protein, natural flavors, salt, and caramel color. Item 2, “Pea Protein Mince Chicken-Style,” is composed of 57 percent water, 28 percent pea protein, 3 percent sunflower oil, 2.5 percent shea oil, 2.5 percent coconut oil, less than 3 percent yeast extracts, and less than 5 percent natural flavors, rice proteins, salt, lemon powder, and spices Item 3, “Pea Protein Patty Beef-Style,” is composed of 60 percent water, 17 percent pea protein, 7 percent sunflower oil, 4 percent shea oil, 4 percent coconut oil, less than 3 percent methyl cellulose, less than 2 percent onion powder and garlic powder, and less than 5 percent spices, salt, rice protein, natural flavors, caramel color, and potato starch.

Item 4, “Pea Protein Patty Chicken-Style,” is composed of 60 percent water, 16 percent pea protein, 7 percent sunflower oil, 4 percent shea oil, 4 percent coconut oil, less than 3 percent methyl cellulose, and less than 5 percent spices, onion powder and garlic powder, rice protein, natural flavors, yeast extract, salt, and potato starch. Item 5, “Pea Protein Kebab Spiced Lamb-Style,” is composes of 58 water, 16 pea protein, 7 percent sunflower oil, 4 shea oil, 4 percent coconut oil, less than 3 percent methyl cellulose, less that 2 percent onion powder and garlic powder, and less that 5 percent spices, dry parsley, salt, rice protein, natural flavors, caramel color, and potato starch. The manufacturing process for item 1 and item 2 includes seasoning and water addition, mixing with TVP and hydration for 30 minutes, vacuum packaging, freezing, and storage. Item 3 and item 4’s manufacturing process includes emulsion preparation, TVP Hydration for 30 minutes, mixing, forming line (Burger Patty), freezing, packing, and storage. Item 5’s manufacturing process includes emulsion preparation, TVP hydration for 30 minutes, mixing, forming line (kebab), freezing, packing, and storage. The applicable subheading for the plant-based protein bites will be 2106.90.9995, Harmonized Tariff Schedule of the United States (HTSUS), which provides for food preparations not elsewhere specified or included…other…other…other…frozen.. The general rate of duty will be 6.4 percent ad valorem. 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 Timothy Petrulonis at [email protected]
Sincerely,
(for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division