01.28.16
In comments submitted on Jan. 22, the American Herbal Products Association (AHPA) expressed opposition to recent U.S. Customs and Border Protection (CBP) proposals that would change the tariff classification of certain bilberry and blueberry extract powders.
AHPA comments were in response to a Dec. 23, 2015 CBP notice of proposals to revoke three ruling letters, modify two ruling letters and change the tariff classification of these extracts. Numerous AHPA members could be affected by this proposed change, and AHPA expressed opposition to the proposal as part of its goal to maintain appropriate tariff classifications for botanical extracts.
"AHPA views CBP's proposal as directly problematic for importers and marketers of bilberry and blueberry extracts and as presenting potential economic burdens on companies that trade in other herbal extracts," said AHPA President Michael McGuffin. "If this particular CBP proposal becomes the norm we could see inappropriate tariffs applied to many other ingredients derived from botanical sources."
AHPA's comments provided informed insights into how botanical extracts are manufactured, discussed numerous relevant CBP ruling precedents, and encouraged CBP to use the word "extract" in a manner that is consistent with common usage of the word by industry. The comments also expressed AHPA's views that CBP should not automatically classify an extract in a higher tariff category based solely on use of processing such as standardization, purification or enrichment with such technologies as column chromatography.
AHPA's complete comments can be found here.
AHPA comments were in response to a Dec. 23, 2015 CBP notice of proposals to revoke three ruling letters, modify two ruling letters and change the tariff classification of these extracts. Numerous AHPA members could be affected by this proposed change, and AHPA expressed opposition to the proposal as part of its goal to maintain appropriate tariff classifications for botanical extracts.
"AHPA views CBP's proposal as directly problematic for importers and marketers of bilberry and blueberry extracts and as presenting potential economic burdens on companies that trade in other herbal extracts," said AHPA President Michael McGuffin. "If this particular CBP proposal becomes the norm we could see inappropriate tariffs applied to many other ingredients derived from botanical sources."
AHPA's comments provided informed insights into how botanical extracts are manufactured, discussed numerous relevant CBP ruling precedents, and encouraged CBP to use the word "extract" in a manner that is consistent with common usage of the word by industry. The comments also expressed AHPA's views that CBP should not automatically classify an extract in a higher tariff category based solely on use of processing such as standardization, purification or enrichment with such technologies as column chromatography.
AHPA's complete comments can be found here.
