CLA-2-29:OT:RR:NC:2:235

Mr. Curt Treu
Epomix Corporation
163 Hillcrest Drive
Barrington, IL 60010-4754

RE: The tariff classification of various catalysts from China

Dear Mr. Treu:

In your letter dated February 15, 2011 you requested a tariff classification ruling.

The following four products you are requesting classification on are listed below:

Puma ® 2210 consists of 98% Bis(dimethylaminopropyl)methylamine (CAS# 3855-32-1).

Puma ® 2220 consists of 97% Tris (3-dimethylamino)propylamine (CAS # 33329-35-0).

Puma ® 2230 consists of Triethylenediamine (CAS # 280-57-9), Ethyleneglycol (CAS # 107-21-1) and Hydoxypropylammonium diazabicyclo [2,2,2] octane-2-ethylhexanoate, N-2-(P84-696) (CAS # 103969-79-5).

Puma ® 2240 consists of Triethylenediamine (CAS # 280-57-9), Ethyleneglycol (CAS # 107-21-1), Butanediol, 1,4 (CAS # 110-63-4) and Hydoxypropylammonium diazabicyclo [2,2,2] Octane-2-ethylhexanoate, N-2-(P84-696) (CAS # 103969-79-5).

Your letter also states that the remainder of the chemicals present in the Puma® 2210 and Puma® 2220 are reaction residues left over from the chemical reactions which produced the given products. You indicate that the products are all used as catalysts in the production of polyurethane foam. In our phone conversation you stated that none of the products under consideration are used to delay or retard the chemical reactions.

The applicable subheading for Puma® 2210 and Puma® 2220 will be 2921.29.0055, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Amine-function compounds: Acyclic polyamines and their derivatives; salts thereof: Other: Other.” The rate of duty will be 6.5 percent ad valorem.

The applicable subheading for Puma® 2230 and Puma® 2240 will be 3815.90.50000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Reaction initiators, reaction accelerators and catalytic preparations, not elsewhere specified or included: Other: Other.” The rate of duty will be 5 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).

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