Re: Fruit or Vegetable Chips or Crisps CCSB Contact: Allison L. Austin Telephone (703) 838-8864 austin@nmfta.org Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class FOODSTUFFS GROUP: subject to item 72000 74800 Snack Foods, flavored or not flavored, viz.: Chips, Puffs, Sticks or Twists, NOI; Crisps, NOI, see Note, item 74801; Potato, Corn or Banana Chips or Crisps; Snack Foods, NOI; [Other Articles Listed Not Involved.] In boxes, drums or Packages 1000, 2387 or 2416, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than 1... 400 Sub 2 1 but less than 2... 300 Sub 3 2 but less than 4... 250 Sub 4 4 but less than 6... 150 Sub 5 6 but less than 8... 125 Sub 6 8 but less than 10... 100 Sub 7 10 but less than 12... 92.5 Sub 8 12 but less than 15... 85 Sub 9 15 or greater... 70 74801 NOTE Not Involved. FRUITS OR VEGETABLES, DRIED, GROUP: subject to item 77000 77020 Apples, in bags, boxes or drums: Sub 1 In retail containers weighing each less than 5 ounces... 150 Sub 2 Other than in retail containers, or in retail containers weighing each 5 ounces or more... 65 77140 Fruits, dried or evaporated, NOI, not candied, crystallized, glazed nor stuffed, in bags, boxes, drums or Packages 1264 or 2445... 65 77400 Vegetables, dried or evaporated, NOI, in bags, boxes, drums or Packages 510 or 1264... 70 2014 National Motor Freight Traffic Association, Inc. Subject 10, Page 1 of 5
Proposed Classification Provisions Item Description Class FOODSTUFFS GROUP: subject to item 72000 74800 Snack Foods, flavored or not flavored, viz.: Chips, Puffs, Sticks or Twists, NOI; Crisps, NOI, see Note, item 74801; Fruit or Vegetable Chips or Crisps; Potato or Corn Chips or Crisps; Snack Foods, NOI; [Other Articles Listed No Change.] In boxes, drums or Packages 1000, 2387 or 2416, subject to Items 170 and 171 and having a density in pounds per cubic foot of: Sub 1 Less than 1... 400 Sub 2 1 but less than 2... 300 Sub 3 2 but less than 4... 250 Sub 4 4 but less than 6... 150 Sub 5 6 but less than 8... 125 Sub 6 8 but less than 10... 100 Sub 7 10 but less than 12... 92.5 Sub 8 12 but less than 15... 85 Sub 9 15 but less than 22.5... 70 Sub 10 22.5 but less than 30... 65 Sub 11 30 or greater... 60 74801 NOTE No Change. FRUITS OR VEGETABLES, DRIED, GROUP: subject to item 77000 77020 Apples, etc... No Change 77140 Fruits, dried or evaporated, NOI, not candied, crystallized, glazed nor stuffed, etc.... No Change 77400 Vegetables, dried or evaporated, NOI, etc.... No Change Analysis Research Project 1183 This proposal is based on information developed through Research Project 1183, which was initiated in May 2013 to address interpretation issues and investigate the transportation characteristics of various dried fruits or vegetables. The information in this proposal encompasses a section of that research pertaining to those articles identified as fruit or vegetable chips or crisps. Several interpretation questions have arisen over the years regarding the applicable provisions for these commodities. As a part of Research Project 1183, 83 potential manufacturers or shippers of fruit or vegetable chips or crisps, and five trade associations believed to represent those companies, were sent questionnaires. Initial mailings were sent in July of 2013, and for non-respondents, a second, follow-up questionnaire was sent in September of 2013 inviting them to participate in Subject 10, Page 2 of 5 2014 National Motor Freight Traffic Association, Inc.
the research. Additional questionnaires were sent as the CCSB was made aware of other potential industry contacts. Of the companies contacted, none provided usable information specific to the transportation characteristics of fruit or vegetable chips or crisps. Regarding the five trade associations contacted, one responded that they did not represent manufacturers or shippers of the involved articles, and one provided a list of contacts to be included in the mailing list. No response was received from the remaining associations. About Fruit or Vegetable Chips or Crisps Fruit or vegetable chips or crisps are generally bake-dried convenience foods made from fruits or vegetables such as apples or carrots. They are marketed primarily as healthy snacks. As shown in the photos below, the involved articles are lightweight round or chipshaped slices or pieces. A flavoring, including a sugar or spice coating may be added; however, the main ingredients are the slices or pieces of dried fruits or vegetables. This makeup of the products has resulted in interpretation questions regarding their categorical identification, i.e. dried fruits or vegetables versus chips or crisps versus snack foods. Transportation Characteristics Density Information of record for fruit or vegetable chips or crisps includes 212 density observations submitted by carriers, collected during CCSB dock surveys and obtained from the CCSB Density Study 1. The products range in density from 2.40 to 11.42 pcf, with an average of 3.90 pcf. A frequency distribution is shown on the following page. 1 The Density Study is part of an ongoing effort by the CCSB to collect information on actual shipments; it is not tied to any particular research project, nor does it target any particular product category. Carriers that choose to participate in the study periodically submit shipment data captured through their respective freight auditing programs. The data is identified by NMFC item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used. 2014 National Motor Freight Traffic Association, Inc. Subject 10, Page 3 of 5
Frequency Distribution for Fruit or Vegetable Chips or Crisps % of Figures in Interval 80.00% 60.00% 40.00% 20.00% 0.00% 67.92% 27.36% 0.00% 0.00% 2.36% 1.89% 0.47% 0.00% 0.00% 0.00% 0.00% Density Intervals (pcf) While the majority of the known density observations are in the 2 but less than 4 pcf density interval, when compared to products identified as chips or crisps currently moving under the provisions of item 74800, including, but not limited to, potato or corn chips or crisps, the density range and average are comparable, with those chips or crisps ranging in density from 1.40 to 12.98 pcf, with an average of 4.31 pcf. Frequency Distribution for Chips or Crisps Currently Moving Under Item 74800 % of Figures in Interval 60.00% 40.00% 20.00% 0.00% 55.54% 30.20% 0.00% 3.69% 2.85% 4.53% 3.02% 0.17% 0.00% 0.00% 0.00% Density Intervals (pcf) Subject 10, Page 4 of 5 2014 National Motor Freight Traffic Association, Inc.
Handling and Stowability Generally, fruit or vegetable chips or crisps, like other types of chips or crisps, are tendered in fiberboard boxes on lift truck skids or pallets. Packages may include pictorial markings instructing the carrier to Do Not Stack. As with other food, care must be taken to avoid stowing the involved commodities with hazardous materials or other freight that may pose a contamination risk. However, no significant handling or stowability issues have been reported. Liability Fruit or vegetable chips or crisps are not likely to damage other freight, but they may be damaged by freight with which stowed or by the elements. As with other foodstuffs, these products require extra care or attention to avoid contamination. No value information was reported for fruit or vegetable chips or crisps, and there is no indication of a claims problem. Relationship to CCSB Policies and Guidelines CCSB policy calls for establishing or amending classifications for commodities that are a source, or potential source, of interpretation disputes so as to eliminate or avoid those disputes. The CCSB has received several interpretation inquiries regarding the applicable provisions for fruit or vegetable chips or crisps. The composition of the involved products has resulted in questions regarding whether they are most appropriately categorized as dried fruits or vegetables, or as chips or crisps. Current CCSB opinions hold the provisions of item 74800, for Chips, NOI, Crisps, NOI, or Snack Foods, NOI, applicable; however, interpretation questions still persist. This proposal would address the interpretation issues by naming fruit or vegetable chips or crisps in the description of item 74800. Information on this record shows that fruit or vegetable chips or crisps are not only lightweight snacks similar to other types of chips or crisps currently listed under the provisions of item 74800, but they also exhibit comparable transportation characteristics. Densities of fruit or vegetable chips or crisps range from 2.40 to 11.42 pcf, with an average of 3.90 pcf, as compared with 1.40 to 12.98 pcf and an average of 4.31 pcf for products identified as chips or crisps currently moving per the density-based provisions of item 74800. The respective handling, stowability and liability characteristics are also similar. While individually the density ranges and distributions for these commodities might not suggest full-scale density provisions, the larger snack food category is shown to have a broader distribution of densities. This proposal would amend the description of item 74800 to specifically name Fruit or Vegetable Chips or Crisps, which would address the interpretation issues, while grouping the products with related commodities possessing comparable transportation characteristics. The reference to Banana Chips or Crisps would be removed in the interest of simplification. Additionally, to reflect current policy regarding full-scale density items, the density scale in item 74800 would also be extended to provide the CCSB s standard 11-subprovision progression 2. Based on the information of record, this proposal, as docketed, is in keeping with CCSB policy and precedent. 2 The CCSB s standard 11-subprovision density scale includes reference to Item (Rule) 170, the inadvertence clause, and Item (Rule) 171, the bumping privilege. 2014 National Motor Freight Traffic Association, Inc. Subject 10, Page 5 of 5