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Milk Chocolate Covered Pretzels from Japan

Crunchy pretzels coated in milk chocolate, containing over 10% milk solids from the chocolate coating. Classified under HTS 2106.90.66.00 as a food preparation not elsewhere specified, featuring dairy products from chapter 4 note 1 like milk powder in the chocolate. The milk solids content exceeds the threshold, distinguishing it from plain confections.

Duty Rate — Japan → United States

12.5%

Rate breakdown

9903.05.4912.5%Section 301 (forced labor) — Japan (col1 rate < 12.5 percent): MFN < 12.5% → total duty capped at 12.5%

Import Tips

Verify milk solids content via lab analysis to confirm >10% threshold and chapter 4 dairy note compliance

Provide detailed ingredient breakdown and certificates of analysis to avoid reclassification to chocolate headings

Watch for additional U.S. note 1 dairy quotas; ensure product isn't subject to over-quota duties