Tariff Classification Advance Ruling
All-natural dog biscuit/chew


Mr. Bikram Singh
Advance Pet Products (Canada)
105 Habourtown Cres.
Brampton, ON L6V 4P3

Date of issuance of ruling: July 27, 2016

This is in response to your request for an advance ruling on the tariff classification of the all-natural dog biscuit/chew. This product is exported from MLA Inc. PVT. Ltd., Lalitpur, Nepal.

TRS Number: 275043
Classification Number: 2309.10.00.10
Effective Date: July 27, 2016

Product Description

This product is an all-natural dog biscuit/chew composed of cow milk, yak milk, salt, lime, herbs and water. Corn starch is added for coagulation but is later removed. The ingredients are mixed, heated to a high temperature and baked to achieve the hardened biscuit and packaged for retail sale.

Analysis and Justification

Heading 23.09 of the Customs Tariff provides for “Preparations of a kind used in animal feeding.” Explanatory Notes to Heading 23.09 read in part, “Biscuits for dogs or other animals, usually made with flour, starch or cereal products mixed with greaves or meat meal.” This product meets the terms of the heading and the explanatory notes.


Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Rules for the Interpretation of the Harmonized System. Section 11 of the Customs Tariff states that in interpreting the headings and subheadings, regard shall be had to the World Customs Organization's (WCO) Explanatory Notes to the Harmonized Commodity Description and Coding System.

General Interpretative Rule 1 (GIR 1) directs that titles of Sections, Chapters and sub-Chapters are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the heading and any relative Section and Chapter Notes. Similarly, General Interpretative Rule 6 (GIR 6) directs that classification shall be determined according to the terms of those subheadings and any related Subheading Notes.

The all natural dog biscuit/chew is classified 2309.10.00.10 as “Preparations of a kind used in animal feeding, dog or cat food, put up for retail sale, biscuits, whole or kibbled”, in accordance with GIR 1.

Legislative/Administrative References

This ruling has been issued under paragraph 43.1(1)(c) of the Customs Act and will be honoured by the CBSA for future importations of the goods specified, provided the material facts and circumstances remain as originally presented; all conditions in the ruling have been met; the ruling has not been modified, revoked, revised, or cancelled; and the Customs Tariff legislation has not changed. Should there be a change in the material facts or circumstances pertaining to the goods, you must notify the CBSA as soon as possible. You may request that the advance ruling be modified or revoked as of the date of the change.

Importers should quote the advance ruling number at the time of importation in either the description field of the B3 entry document or on the Canada Customs Invoice. Exporters or producers should quote the advance ruling number on the Certificate of Origin or commercial invoice accompanying the goods.

Should you disagree with this advance ruling, you may file a dispute notice under subsection 60(2) of the Customs Act within 90 days of the date of issuance. Please see the procedures outlined in Appendix C of the CBSA’s Memorandum D11-11-3, Advance Rulings for Tariff Classification.

This advance ruling is considered “reason to believe” for the purposes of section 32.2 of the Customs Act and as described in Memorandum D22-1-1, Administrative Monetary Penalty System.

All Memoranda referenced in this letter may be accessed on the CBSA website.

Consent to the Public Release of the Advance Ruling

As per your consent statement, we will release this advance ruling to the public, in both official languages, in accordance with the procedures described in Memorandum D11-11-3.

CBSA Contact

Mark Grant
Manager, Tariff Policy Unit 'B'
Trade Policy Division
Headquarters, Ottawa

File Number


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