NCS/ARS/CL/10420

1.       You have requested for advance rulings and the guidance of the Nigeria Customs Service on the tariff classification, related fiscal policy measure and other taxes for the Dove cleansing products imported as raw materials (noodles).

PRODUCTS DESCRIBED AS CLEANSING BAR NOODLES

The products are extruded noodles (pellets) of a solid cleansing bar base intended for importation in bulk as an intermediate manufacturing material for the local milling, plodding, stamping, finishing and packaging of Dove Beauty Bar in Nigeria. According to the information supplied by the applicant, the cleansing system of the base is founded on the mild synthetic organic surface-active agent Sodium Lauroyl Isethionate (SLI), formulated together with moisturizing cream and other skin-conditioning constituents. The base should contain no soap and no Total Fatty Matter (TFM). The noodles are not put up for retail sale and are not presented in the form of bars, cakes or moulded pieces or shapes.

TARIFF CLASSIFICATION

Extruded noodles in bulk, destined for substantial further manufacturing operations, are an industrial raw material and are not moulded pieces or shapes put up for use as soap, The noodles are classifiable in heading 34.02, which covers organic surface-active agents (other than soap) and surface-active preparations. As a formulated mixture of a surfactant with moisturizing and conditioning constituents, rather than a single surface-active agent of defined ionic character, and not being put up for retail sale, the goods are a surface-active preparation of subheading 3402.90 -  ‘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 34.01’.

The tariff classification of the dove syndet noodles presented as raw materials for the production of dove cleansing bars is 3402.90.00.00 - ‘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 34.01’; -Other at 20% Rate of Duty and 7.5% VAT in the ECOWAS CET 2022 - 2027.

LEGAL FRAMEWORK & JUSTIFICATION

GIR 1 & 6