CLA-2-38:OT:RR:NC:N2:235
Mr. Don Zarin
Holland & Knight LLP
2099 Pennsylvania Ave., N.W. Suite 100
Washington D.C. 20006
RE: The tariff classification of various formulations of chemical products containing n-propyl bromide from Israel
Dear Mr. Zarin:
In your letter dated April 22, 2008, on behalf of AmeriBrom, Inc., you requested a tariff classification ruling. In that letter, you asked that confidential treatment be given. Your request for confidential treatment was reviewed and denied. A letter regarding this matter was sent to you on April 30, 2008. You indicate that the products which will be imported consist of various formulations of N-Propyl Bromide.
The first product, n-propyl Bromide C30 – Plus, is composed of n-propyl bromide and 1,2-epoxybutane. 1,2-epoxybutane is an epoxide, added specifically as a stabilizer for the preservation for n-propyl bromide. Based on Chapter Note 1(f), separate chemically defined organic compounds with an added stabilizer necessary for the preservation or transport remain classified in Chapter 29. n-propyl bromide, a straight chain alkyl bromide, is a brominated derivative of an acyclic hydrocarbon (propane). As indicated in your letter, the product will be used as an intermediate in the manufacture of adhesive products. It consists of the following ingredients:
n-propyl bromide - (CAS-106-94-5)
1,2-epoxybutane - (CAS-106-88-7)
The second product, n-propyl Bromide DC, is stated to be used as a solvent in the dry cleaning industry. It consists of the following ingredients:
n-propyl bromide - (CAS-106-94-5)
1,2-epoxybutane - (CAS-106-88-7)
2-methyl-2-propanol - (CAS-75-65-0)
dimethoxymethane -(CAS-109-87-5)
The third product, Propyl Bromide Lenium GS is stated to be used as a general use solvent, in vapor degreasing processes. It is used to remove contaminants such as oils, greases, adhesives, resins and flux residues. It consists of the following ingredients:
n-propyl bromide - (CAS-106-94-5)
1,2-epoxybutane - (CAS-106-88-7)
2-methyl-2-propanol - (CAS-75-65-0)
dimethoxymethane - (CAS-109-87-5)
The fourth product, Propyl Bromide Lenium ES is also designed for use as a solvent in vapor degreasing processes of a similar nature. It is also used as a solvent, to remove contaminants and residues from circuit assemblies. It consists of the following ingredients:
n-propyl bromide - (CAS-106-94-5)
1,2-epoxybutane - (CAS-106-88-7)
2-methyl-2-propanol - (CAS-75-65-0)
Dimethoxymethane - (CAS-109-87-5)
2-propanol - (CAS-67-63-0)
The applicable subheading for first product, N-Propyl bromide C30-Plus will be 2903.39.1550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Halogenated derivatives of hydrocarbons: Fluorinated, brominated or iodinated derivatives of acyclic hydrocarbons: Other: Alkyl bromides; Other.” The rate of duty will be free.
The applicable subheading for the other three products, N-propyl bromide DC, Propyl bromide Lenium GS, and Propyl bromide Lenium ES will be 3814.00.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Organic composite solvents and thinners, not elsewhere specified or included; prepared paint or varnish removers: Other: Other.” The rate of duty will be 6 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
Articles classifiable under subheading 3814.00.5090, HTSUS, which are products of Israel, may be entitled to duty free treatment under the United States-Israel Free Trade Area Implementation Act of 1985, upon compliance with all applicable regulations.
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Paul Hodgkiss at 646-733-3046.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division