CLA-2-29:RR:NC:2:240 L87476

Mr. Joseph J. Chivini
Austin Chemical Company, Inc.
1565 Barclay Boulevard
Buffalo Grove, Illinois 60089

RE: The tariff classification of p-Hydroxymethylbenzoate, CAS # 99-76-3, imported in bulk form, from China

Dear Mr. Chivini:

In your letter dated August 18, 2005 you requested a tariff classification ruling.

The subject product, p-Hydroxymethylbenzoate, also known as Benzoic acid, 4-hydroxy-, methyl ester, is an ester of a carboxylic acid with phenol function. The product is indicated for use as a pharmaceutical intermediate.

The applicable subheading for p-Hydroxymethylbenzoate will be 2918.29.7500, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxylic acids with phenol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Other: Other: Other….. The rate of duty will be 6.5 percent ad valorem.

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 Stephanie Joseph at 646-733-3268.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division