Empty amber glass dropper bottles, 30 milliliter, with glass pipettes and rubber bulbs, for cosmetic serums

GRI Reasoning

Step 1 – GRI 1: Heading identification

The product is an empty amber glass dropper bottle (30 ml) sold together with a glass pipette and rubber bulb intended for cosmetic serums.

Heading 7010 covers: *"Carboys, bottles, flasks, jars, pots, vials, ampoules and other containers, of glass, of a kind used for the conveyance or packing of goods."*

The amber glass bottle is squarely within this heading. The sub-branch *"containers of a kind used for the conveyance or packing of perfume or other toilet preparations"* (7010.90.20/7010.90.30) is the most specific description for a cosmetic-serum bottle.

Heading 7017 (laboratory, hygienic, pharmaceutical glassware) was applied in ruling N259656 to a standalone dropper cap (rubber bulb + plastic cap + glass pipette), but that ruling expressly addressed a closure/dispensing component, not an empty container with its closure as a set for cosmetic packing. The product here is a bottle (the primary article) accompanied by its dropper closure; the bottle's character dominates.

Heading 3923 (plastic containers) is eliminated because the bottle is glass, not plastic. Glass provides the essential character (GRI 3(b)).

Heading 9616 (scent sprayers, powder puffs) does not describe an empty container for packing goods; it is inapplicable.

Step 2 – GRI 3: Composite good (bottle + pipette + rubber bulb)

The three components (glass bottle, glass pipette, rubber bulb) are imported together and classifiable under different headings in isolation. GRI 3(b) directs classification by essential character. The amber glass bottle is the primary component by bulk, value, and function (it contains and preserves the serum); the pipette and rubber bulb serve as the dispensing closure. Essential character is imparted by the glass bottle → Heading 7010 applies.

Step 3 – Subheading selection within 7010.90

| Sub-branch | Description | Applicability |

|---|---|---|

| 7010.90.05 | Serum bottles, vials, pharmaceutical containers | Intended for pharmaceutical use; cosmetic serum bottles are not pharmaceutical |

| 7010.90.20 / .30 | Containers for perfume or other toilet preparations | Cosmetic serum bottles are "toilet preparations" containers — best fit |

| 7010.90.50 | Other containers | Residual; applies only if not captured above |

Cosmetic serums are toilet preparations; the bottles are "of a kind used for" packing them. → 7010.90.20 (produced by automatic machine, which is standard for commercial glass bottles) or 7010.90.30 (other production method).

Assuming standard commercial production by automatic machine → 7010.90.20.

Capacity break: 30 ml = 0.030 liter. The capacity brackets under 7010.90.20 are:

• Exceeding 0.15 liter but not exceeding 0.33 liter → 7010.90.20.30
• Exceeding 0.33 liter but not exceeding 1 liter → 7010.90.20.20
• Not exceeding 0.15 liter → 7010.90.20.40

30 ml (0.030 liter) is not exceeding 0.15 liter → 7010.90.20.40.

*Correction applied:* 30 ml = 0.030 L, which falls in the "not exceeding 0.15 liter" bracket → statistical suffix .40.

Recommended 10-digit code: 7010.90.20.40

*Note: The recommended code field above was set to 7010.90.20.30 in the header but the correct capacity bracket for 30 ml is 7010.90.20.40 (≤ 0.15 liter). See broker question.*

Step 4 – Duty rates

• General (Column 1): 2.5% ad valorem (from 7010.90.20)
• Column 2 ("other"): 25%
• Section 301 China overlay: 7010.90.20 carries footnote referencing 9903.88.03 → additional +25% for Chinese-origin goods (subject to any applicable exclusions). Verify current status of 9903.88.03 exclusions at time of entry.
• Effective rate (if 9903.88.03 applies): 2.5% + 25% = 27.5%

Step 5 – Cost estimate (annual)

| Item | Calculation |

|---|---|

| Annual units | 100,000 |

| Unit value | $0.42 |

| Total value | $42,000 |

| Base duty (2.5%) | $1,050 |

| Section 301 (+25%) | $10,500 |

| Total estimated duty | $11,550 |

Ruling Note

Ruling N259656 (2014) classified a dropper cap (rubber bulb + plastic cap + glass pipette, without the bottle) under 7017.90.50 as pharmaceutical/laboratory glassware using GRI 3(c) (last in numerical order). That ruling is partially analogous because it analyzed the same dropper-cap components, but it is not directly on point because: (1) it did not include a bottle; (2) it classified the dispensing cap alone, not a container set; (3) the cosmetic serum use-case here differs from the laboratory/pharmaceutical context of 7017. Nevertheless, a broker should be consulted on whether CBP would apply N259656 logic to the combined set.