In ruling NY N313708, Customs and Border Protection (CBP) discussed the classification of a cleaning compound in the form of putty called “Rodico.” The most common uses include removing oil and fingerprints from watch parts, and cleaning movement plates, bridges, dials, balance pivots, train wheel pivots, and gears. “Rodico” also removes oil, crud, dust, and debris from tools, removes dirt and oils from jewelry, and helps pick up and maneuver small watch parts like jewels and screws. CBP determined that the subject product is a cleaning preparation, not having a basis of soap or other organic surface-active agents.

Thus, CBP determined that the applicable subheading for “Rodico” is 3402.90.5030, HTSUS, which provides for Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Other: Other: Other: Cleaning preparations. The general rate of duty is 3.7 percent ad valorem.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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