Title
Tariff and misdeclaration issues on iodized salt
Law
Boc Memorandum Circular No. 299-2000
Decision Date
Jul 25, 2000
The Bureau of Customs addresses concerns raised by Health Secretary Alberto G. Romualdez regarding the misdeclaration of iodized salt due to a tariff discrepancy, prompting a review of customs duties to ensure compliance with the ASIN Law.

Subject: iodized salt tariff and misdeclaration

  • The circular addresses tariff and misdeclaration issues on iodized salt in relation to customs duties.
  • The tariff issue concerns the classification and duty rates for iodized salt under HS Hdg. No. 2501.00 10.
  • The misdeclaration concern is tied to a perceived “2% differential” between duty rates applied to industrial salt (HS Hdg. No. 2501.00 90) and iodized salt.
  • The concern arises from alleged misdeclaration for customs duties purposes, where iodized salt may be declared as industrial salt (or treated as industrial salt for duty purposes).

Tariff modification and effective date

  • The tariff on iodized salt was modified from 3% to 5% ad valorem.
  • The modification was made by Executive Order No. 208.
  • The modification became effective on 15 March 2000.
  • The tariff change is presented as the controlling adjustment affecting iodized salt duty rates at the time relevant to the misdeclaration concern.

Reference tariff classification and duty rates

  • Iodized salt is identified for tariff purposes as HS Hdg. No. 2501.00 10.
  • Industrial salt is identified for tariff purposes as HS Hdg. No. 2501.00 90.
  • The prior iodized salt duty rate was 3% ad valorem before the Executive Order No. 208 modification.
  • The adjusted iodized salt duty rate is 5% ad valorem after the modification.

Role of the Tariff Commission hearing

  • A public hearing was conducted on 13 November 1998 prior to the issuance of Executive Order No. 208.
  • At the hearing, the Bureau of Customs position was that iodized salt is distinguishable from industrial salt.
  • The hearing position maintained that iodized salt is therefore not susceptible to misdeclaration as industrial salt for customs purposes.

Compliance concern under ASIN Law

  • The circular reflects concern from the Health Department regarding non-observance of RA 8172 (ASIN Law).
  • The concern is triggered by perceived misdeclaration of iodized salt as industrial salt.
  • The issue is framed as affecting compliance with the ASIN Law requirement for observance of iodization-related standards.
  • The circular links the Health Department’s concern to the customs treatment that allegedly enables misdeclaration.

Bureau of Customs instruction on enforcement efforts

  • The circular directs guidance to the Bureau that it should adopt more extra efforts and measures to address “misdeclaration.”
  • The misdeclaration referred to is the perceived practice involving iodized salt being handled or declared as industrial salt for customs duties purposes.
  • The directive is tied to the Bureau’s enforcement and operational response to the Health Department’s concern.
  • The circular’s guidance is directed for purposes of administrative action within the Bureau of Customs.

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