AAR held that the imported product "Flamberge," a bio-stimulant,...

AAR held that the imported product "Flamberge," a bio-stimulant, is not classifiable as a fertilizer under CTH 3101 but as a plant growth regulator under CTH 3808, specifically CTI 38089340. The Authority found that, although the product contains nitrogen (7.90%), its essential character is derived from amino acids and peptides (minimum 46.9% by weight), which act as active ingredients. These components function not as nutrients compensating soil deficiency but as agents stimulating plant growth, metabolism, root development, nutrient absorption and stress management. Applying GRI 1 and Rule 3(a), the more specific description as plant growth regulator was preferred over fertilizer classification.