CLA-2-29:OT:RR:NC:N3:140
Mark Embury
CanStar International, Inc.
13551 SW 135th Avenue, Unit 308 Miami, FL 33186
RE: The tariff classification of Triacetin (CAS No. 102-76-1) in bulk form, from Poland
Dear Mr. Embury:
In your letter dated October 16, 2024, you requested a tariff classification ruling.
Triacetin (CAS No. 102-76-1) is also known as glyceryl triacetate. It is a triacetate ester of glycerol. As per Hawley's Condensed Chemical Dictionary (Sixteenth Edition), glycerol is a trihydric (polyhydric) alcohol. You indicate that triacetin is a plasticizer used in making acetate tow filters.
You suggest classification in subheading 2915.39.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Saturated acyclic monocarboxylic acids and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Esters of acetic acid: Other: Other: Other: Other: Other. We disagree. Based on the chemical structure, triacetin is more specifically provided for elsewhere.
The applicable subheading for triacetin will be 2915.39.4700, HTSUS, which provides for Saturated acyclic monocarboxylic acids and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Esters of acetic acid: Other: Other: Other: Acetates of polyhydric alcohols or of polyhydric alcohol ethers. Pursuant to General Note 13, HTSUS, the rate of duty will be free. Triacetin is listed in Table 1 of the Pharmaceutical Appendix.
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 at https://hts.usitc.gov/.
This merchandise may be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency (EPA). Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at 800-471-7127, by e-mailing to [email protected], or by visiting their website at www.epa.gov.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177).
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, please contact National Import Specialist Merari Ortiz at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division