The tariff classification of bakery products from Germany

N361555June 9, 2026CLA-2-19:OT:RR:NC:N5228
CATEGORY: Classification
TARIFF NO.: 1905.90.1049
Lucas Theo RehaagGerman American Chamber of Commerce, Inc.120 Wall Street, 20th FloorNew York, NY 10005RE: The tariff classification of bakery products from GermanyDear Mr. Rehaag:In your letter dated
May 15, 2026
, you requested a tariff classification ruling on behalf of your client,EuroSummer, Inc. An ingredients breakdown, product specification sheets and pictures of five productsaccompanied your inquiry.The first product, “Frozen Bavarian Pretzel Buns,” are described as lye rolls with a football design, that arelye-coated, fully baked and deep-frozen. The product is said to contain wheat flour, water, yeast, canola oil,salt, malted wheat flour, wheat gluten, ascorbic acid and sodium hydroxide. The second product, “Frozen German Pretzels,” are described as a Swabian-style pretzel-shaped lye-leavenedpastry with a slit and salt topping that is ready-baked and deep-frozen. The product is said to contain wheatflour, water, yeast, canola oil, salt, wheat walt flour, wheat gluten, a flour treatment agent consisting ofascorbic acid and an acidity regular consisting of sodium hydroxide.The third product, “Frozen Six Seed Sourdough Bread,” is described as a multigrain bread that isready-baked and deep-frozen. The product is said to contain water, sourdough (rye flour, water), wheat flour,rye flour, oat flakes, sunflower seeds, rye groats, flaxseeds, yeast, salt, wheat gluten and roasted barley malt.The fourth product, “Frozen Alpine Rye Sourdough Loaf,” is described as a rye bread that is ready-baked anddeep-frozen. The product is said to contain wheat flour, water, sourdough (rye flour, water), rye flour, yeast,salt, wheat gluten and roasted barley malt.The fifth product, “Frozen Pumpkin Seed Rolls,” are described as small wheat bakery products with pumpkinseeds that are pre-baked and deep frozen. The product is said to contain wheat flour, water, pumpkin seeds,rye flour, salt, yeast, ground roasted barley malt, wheat malt flour, a flour treatment agent consisting ofascorbic acid, in addition to enzymes consisting of alpha-amylase and hemicellulose.
The applicable subheading for products, “Frozen Bavarian Pretzel Buns,” “Frozen German Pretzels,” “FrozenSix Seed Sourdough Bread,” “Frozen Alpine Rye Sourdough Loaf,” and “Frozen Pumpkin Seed Rolls,” willbe 1905.90.1049, Harmonized Tariff schedule of the United States (HTSUS), which provides for bread,pastry cakes, biscuits and other bakers’ wares, whether or not containing cocoa…other… bread, pastry,cakes, biscuits and similar baked products ... frozen ... other. The general rate of duty will be free.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 othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties 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 eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This merchandise is subject to The Public Health Security and Bioterrorism Preparedness and Response Actof 2002 (The Bioterrorism Act), which is regulated by the Food and Drug Administration (FDA). Information on the Bioterrorism Act can be obtained by calling FDA at 301-575-0156, or at the Web site www.fda.gov/oc/bioterrorism/bioact.html.
This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Timothy Petrulonis at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division