The comment was a response to a December 23, 2015 CBP notice of proposals to “revoke three ruling letters, modify two ruling letters and change the tariff classification” of these berry extracts. The association said many of its members will be affected by this change if implemented.
“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,” AHPA President Michael McGuffin said in a press release. “If this particular CBP proposal becomes the norm we could see inappropriate tariffs applied to many other ingredients derived from botanical sources.”
One main disagreement with the proposal is the use of the word “extract,” which AHPA said the CBP should’ve used “in a manner that is consistent with common usage of the word by industry.“
According to AHPA, the 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.”
The full comment can be read here.