CLA-2-29:S:N:N7:239 883084

Ms. Kathleen Crawford
BDP International Inc.
1017 4th Avenue
Lester, PA 19029-1813

RE: The tariff classification of d-limonene (CAS# 5989-27-5) and orange terpenes from Brazil.

Dear Ms. Crawford:

In your letter dated February 2, 1993, written on behalf of your client, PDM, Pine Derivatives Marketing, you requested a tariff classification ruling.

The applicable subheading for d-limonene will be 2902.19.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for other cyclanes, cyclenes and cycloterpenes. The rate of duty will be 5 percent ad valorem.

The applicable subheading for orange terpenes, a terpenic by- product of orange oil, will be 3301.90.0000, HTS, which provides for essential oils (terpeneless or not), including concretes and absolutes; resinoids; concentrates of essential oils in fats, in fixed oils, in waxes or the like, obtained by enfleurage or maceration; terpenic by-products of the deterpenation of essential oils; aqueous distillates and aqueous solutions of essential oils. The rate of duty will be free.

In order to determine the applicable classification for these products it is necessary that the importer furnish information on the supplier's letterhead indicating the precise extraction process employed, complete chemical composition and in the case of d'limonene, its optical rotation.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Sincerely,

Jean F. Maguire
Area Director
New York Seaport