CLA-2-29:OT:RR:NC:N2:240
Ms. Laura Lyons
EFI, Inc.
6750 Dumbarton Circle
Fremont, CA 94555
RE: The tariff classification of EFI Part #45130696 - Octyl palmitate, CAS No. 29806-73-3; EFI Part #45132064 - Isopropyl myristate, CAS No. 110-27-0; and EFI Part #43132065 - EFI Cleaner from India
Dear Ms. Lyons:
In your letter dated October 3, 2014, you requested a tariff classification ruling.
EFI Part #45130696 consists of Octyl palmitate, CAS No. 29806-73-3, also known as Ethylhexyl palmitate and Hexadecanoic acid, 2-ethylhexyl ester. Octyl palmitate is an ester of palmitic acid.
EFI Part #45132064, composed of Isopropyl myristate, CAS No. 110-27-0 and also known as Tetradecanoic acid, 1-methylethyl ester, is a saturated monocarboxylic acid.
The applicable subheading for EFI Part #45130696 - Octyl palmitate will be 2915.70.0150, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Saturated acyclic monocarboxylic acids and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Palmitic acid, stearic acid, their salts and esters: Other. The rate of duty will be 5 percent ad valorem.
The applicable subheading for EFI Part #45132064 - Isopropyl myristate will be 2915.90.5000, HTSUS, which provides for Saturated acyclic monocarboxylic acids and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Other: Other: Other. The rate of duty will be 3.8 percent ad valorem.
You requested a classification and country of origin ruling for EFI Part #43132065 - EFI Cleaner. You state that Octyl palmitate and Isopropyl myristate from India will be exported to China, Malaysia and the US for blending and processing into EFI Part #43132065 - EFI Cleaner. You stated that this product is marketed for use in cleaning ink residue from print systems. The cleaner will be sold as a bulk cleaner or bottled for sale.
Your inquiry does not provide enough information for us to provide a classification and country of origin ruling for EFI Part #43132065 - EFI Cleaner. Your request for a classification ruling should include the replies to the following questions .What is the cost of the two separate chemicals? What is the cost of processing the chemicals produce the EFI Part #43132065 - EFI Cleaner? Please provide the complete manufacturing flowchart process. Does a chemical reaction occur when the two chemical compounds are blended? Are additional chemicals added to the mixture? Is an intermediate product produced when the two components are blended? Provide marketing materials for the bulk and retail label for the EFI Part #43132065 - EFI Cleaner. Can the bulk cleaner be used in the condition as exported, or does it need to undergo further processing? When this information is available, you may wish to consider resubmission of your request.
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 www.epa.gov.
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 [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division