RE: The tariff classification of Naked Shower Gel, Lush Shower Slime, and Lush Surfactant/Soap Paper from Canada

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363670 August 18, 2026 CLA-2-34:OT:RR:NC:N3:136 CATEGORY: Classification TARIFF NO.: 3401.11.5000 Jill Yewell Lush Manufacturing, LTD 35 Jutland Rd, 307 Etobicoke M8Z 2G6 Canada RE: The tariff classification of Naked Shower Gel, Lush Shower Slime, and Lush Surfactant/Soap Paper from Canada Dear Ms. Yewell: In your letter dated July 24, 2026, you requested a tariff classification ruling on Naked Shower Gel, Lush S hower Slime, and Lush Surfactant/Soap Paper. In your submission, you describe three products. The first product is Naked Shower Gel, also identified as 65459 Snow Fairy Naked Shower Gel. This product is similar to shower gel but is naked/unpackaged. It has a surfactant base with sodium stearate (hardening agent) added. The ingredients are poured into a mold shaped to look like a shower gel bottle and left to harden. The finished product is slightly softer than a typic bar of soap, but firm enough to hold the molded shape. The intended use is to wet the solid bar with water, rub it directly onto your skin or a loofah to create a rich lather, wash your body, and then rinse clean. The second product is Lush Shower Slime, also identified as 60899 Ectoplasm Shower Slime 100g and 60900 Ectoplasm Shower Slime 250g. You state that this product is a semi-solid, scoopable, thick gel like, slime skin cleanser. The product’s composition is formulated sodium laureth sulfate (primary cleansing surfactant) and sodium cocoamphoacetate (mild secondary surfactant). Additional ingredients include glycerin and thickening agents of xanthan gum or carrageenan to create the “slime” texture. The ingredients are poured into recycled plastic pots, either 8.8 oz or 5.5 oz size, with a threaded screw on lid. The product is left to settle before adding the lid and labelling. The intended use is to scoop out a small amount, rub between hands, and apply onto wet skin or on a washcloth/loofah to lather, wash skin with foam, and rinse clean. The third product is Lush Surfactant/Soap Paper, also identified as 65466 Lather Christmas Surfactant Paper. You describe this product as a thin, dry sheet of soap-like paper without a soap base. The sheet is flexible, tearable, lightweight, and naked (not packaged). The product’s composition is formulated with sodium lauryl
or sodium coco sulfate (surfactants), glycerin, carrageenan and cornstarch (thickening agents), and fragrance from essential oil blends. The intended use is to tear off a small piece of the sheet, rub sheet between wet hands, apply onto wet skin or on a washcloth/loofah to lather, wash skin with foam, and rinse clean. The applicable subheading for the three subject products will be 3401.11.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Soap; organic surface-active products and preparations for use as soap, in the form of bars, cakes, molded pieces or shapes, whether or not containing soap; organic surface-active products and preparations for washing the skin, in the form of liquid or cream and put up for retail sale, whether or not containing soap; paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: Soap and organic surface-active products and preparations, in the form of bars, cakes, molded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: For toilet use (including medicated products): Other. The general rate of duty will be free. This merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by visiting their website at www.fda.gov. 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 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 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 Nuccio Fera at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division