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

Mr. Christopher Colford
Mitsui & CO. (U.S.A.), Inc.
200 Park Avenue
New York, NY 10166

RE: The tariff classification of 2-Carboxymethyl-4-nitro benzoic acid, CAS 39585-32-5, from Japan, China, or India.

Dear Mr. Colford:

In your letter dated April 29, 2011, you requested a tariff classification ruling. Your inquiry was submitted to our laboratory for analysis.

Your inquiry pertains to 2-Carboxymethyl-4-nitro benzoic acid. You stated that a CAS number has not been assigned to this compound; however, our laboratory determined that CAS 39585-32-5 is assigned to this compound. 2-Carboxymethyl-4-nitro benzoic acid, also known as Benzeneacetic acid, 2-carboxy-5-nitro, is an aromatic polycarboxylic acid used as a pharmaceutical intermediate.

The applicable subheading for 2-Carboxymethyl-4-nitro benzoic acid will be 2917.39.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Polycarboxylic acids, their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Aromatic polycarboxylic acids, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Other: Other: Other: Products described in additional U.S. note 3 to section VI. The rate of duty will be .6.5 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 Stephanie Joseph at (646) 733-3268.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division