CLA-2 CO:R:C:F 950582 JGH
TARIFF NO: 2924.21.15
Donald E. deKieffer
Pillsbury Madison & Sutro
1667 K Street N.W.
Washington, D.C. 20001
RE: Classification of Trichlorocarbanilide
Dear Mr. deKieffer:
Your inquiry of October 21, 1991, concerns the tariff
classification of trichlorocarbanilide, a product of the United
Kingdom, under the Harmonized Tariff Schedule of the United
States (HTSUS).
FACTS:
Trichlorocarbanilide (TCC), trade name Triclocarban, is a
cyclic amide of the ureine type; it is an aromatic compound said
to be used as a bacteriostat in soaps for disinfectant purposes.
ISSUE:
Whether trichlorocarbanilide is classifiable under the
provision for cyclic amides (including cyclic carbamates) and
their derivatives; salts therof: ureines and their derivatives:
Aromatic: Pesticides: in subheading 2924.21.1500, HTSUS, or as
cyclic amides: ureines and their derivatives: Other: in
subheading 2924.21.3000, HTSUS.
LAW AND ANALYSIS:
For tariff purposes, bactericides and disinfectants are
considered pesticides, as indicated in the Explanatory Notes to
heading 3808, HTSUS. Technical literature submitted in behalf of
the importer shows that TCC is considered a bactericide. In
Kirk-Othmer, Encyclopedia of Chemical Technology, V.7 & V.13, it
is stated that TCC is an antimicrobial agent which is used almost
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exclusively in deodorant soaps, and in deodorant stick
formulations. Another publication recognizes its antimicrobial
action in soap. Skin Microbiology- U. Cal., San Fran., School of
Medicine (1979).
Based on the evidence submitted, it is concluded that the
predominate use, if not the only use, of TCC is as a bactericide.
HOLDING:
Trichlorcarbonilide is classifiable under the provision for
other cyclic amides and their derivatives: Ureines and their
dervatives; salts thereof: Aromatic: Pesticides, in subheading
2924.21.1500, TSUS. The rate of duty is 13.5 percent ad valorem.
Previous rulings on the classification of TCC in conflict
with this decision are being revoked.
Sincerely,
John Durant, Director