CLA-2-29:OT:RR:NC:3:140

Ms. Sabrina Robazza
Sumitomo Rubber USA, LLC
10 Sheridan Drive,
Tonawanda, NY 14150

RE: The tariff classification of Bis[3-(Triethoxysilyl)Propyl]Disulfide from China. Correction to Ruling Number N303404.

Dear Ms. Robazza:

This replaces Ruling Number N303404, dated October 01, 2019, which contained a clerical error. The ruling stated an incorrect reference to a Chapter 99 duty rate. The tariff number indicated in the ruling is not subject to the additional 301 duties at this time. A complete corrected ruling follows.

In your letter dated March 11, 2019, you requested a tariff classification ruling. The materials that you provided were sent to our laboratory for review. That review is now complete. Our determination on the classification of the merchandise is as follows. We apologize for the delay.

The subject product is called Bis[3-(Triethoxysilyl)Propyl]Disulfide (CAS # 56706-10-6). You indicated that it contains: Bis[3-(Triethoxysilyl)Propyl]Disulfide (90 %) with related Silanes (S4 - S8) making up the balance of the product. Our laboratory review indicates that the Silanes are impurities, left over from the chemical reaction, which are allowable based on HTSUS Chapter 29 Note 1.

Bis[3-(Triethoxysilyl)Propyl]Disulfide also known as Triethoxy-[3-(3-triethoxysilylpropyl disulfanyl)propyl]silane is used as chemical intermediate in tire and rubber manufacturing and as a coupling or cross linking agent. The product is a separate chemically defined organic compound containing the following functional groups: organo-silane, disulfide.

The applicable subheading for the Bis[3-(Triethoxysilyl)Propyl]Disulfide will be 2930.90.9130, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Organo-sulfur compounds: Other: Other: Other: Other: Other: Other: Products used principally for rubber processing. The rate of duty will be 3.7 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 the World Wide Web at https://hts.usitc.gov/current.

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


Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division