Ms. Shameel Bowman
Nippon Paint USA Inc.
300 Frank W. Burr Blvd., Suite 10
Teaneck, NJ 07666

RE: The tariff classification of “NC-25” from Japan

Dear Ms. Bowman:

In your letter dated November 7, 2016, you requested a tariff classification ruling on “NC-25.” You have indicated that the product at issue is a polymerization initiator, intended to be used in the manufacture of automotive paints and coatings. Your submission describes the chemical composition as: CAS number 2638-94-0: 4, 4’-Azobia [4-cyanovaleric acid].

The applicable subheading for “NC-25” will be 3815.90.5000, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for Reaction initiators, reaction accelerators and catalytic preparations, not elsewhere specified or included: Other: Consisting wholly of inorganic substances: Other. The general rate of duty will be free.

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. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone at (202) 554-1404, or by visiting their website at

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

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Nuccio Fera at [email protected].


Steven A. Mack
National Commodity Specialist Division