Classification of a Caesar Salad Kit from Canada
Active· CBP ruling HQ 082048· Issued 1989-06-12
Ruling text
HQ 082048
June 12,1989
CLA-2 CO:R:C:G 082048 JGH
CATEGORY: Classification
TARIFF NO.: 2103.90.6040
Mr. Burt Gorenstein
Eticon Consultants Ltd.
130 Slater Street, Suite 630
Ottawa, Canada KIPGE 2
RE: Classification of a Caesar Salad Kit from Canada
Dear Mr. Gorenstein:
Reference is made to your inquiry in regard to the tariff
classification of a Caesar Salad Kit under the Harmonized Tariff
Schedule of the United States (HTSUS).
FACTS:
The kit contains 4 small plastic packets, each containing
one of the ingredients for the finished salad: A Caesar dressing
(which contains the anchovies and eggs), parmesan cheese, bacon
bits, and croutons. The net weight of the contents is said to be
about 5.5 ounces. According to the directions, the contents of
each packet are to be mixed with one half head of chopped romaine
lettuce.
Issue:
The classificaton of a Caesar salad kit under the HTSUS.
LAW AND ANALYSIS:
Classification under the HTSUS is governed by the General
Rules of Intrepretation (GRI). GRI 1 and 2 cover classification
of merchandise in accordance with the various HTSUS headings and
relevant Section or Chapter Notes. GRI 3 deals with the
-2-
classification of products which are, prima facie, classifiable
under two or more headings. GRI 3(c) is concerned with articles
classifiable under different headings which may merit equal
consideration, in which case they are classified under the HTSUS
heading which occurs last in numerical order.
Caesar salad is described as a tossed salad made typically
with romaine, garlic, anchovies, and croutons, and served with a
dressing of olive oil, coddled egg, lemon juice and grated
cheese. Webster's New Collegiate Dictionary (1975). The
imported kit contains salad dressing, croutons, bacon, and
cheese. These are distinct components of the salad and retain
their organoleptic characteristics after bring mixed into a
salad. Therefore there is no one ingredient which imparts an
essential character to the finished salad.
Accordingly, under GRI 3(c) classification under the various
headings for the ingredients would merit equal consideration. In
considering the applicable headings- 0406 for cheese, 1602 for
bacon, 1905 for croutons, and 2103 for sauces and preparations
thereof, subheading 2103.90.6040, HTSUS, applies to other salad
dressings.
HOLDING:
Caesar salad kit, as described above, is classifiable under
the provision for other sauces and preparations therefore, in
subheading 2103.90.6040, HTSUS. The rate of duty is 7.5 percent
ad valorem.
Sincerely,
John Durant, Director
Commercial Rulings Division
Source: rulings.cbp.gov — ruling 082048, retrieved 2026-10-12T05:18:04Z, republished verbatim. This digest is informational; only CBP issues binding rulings.