CLA-2-35:OT: RR:NC:N3:135
Mr. Prashant Khade
NextGen BioProducts
6076 Corte Del Cedro
Carlsbad, CA 92011
RE: The tariff classification of MuLV Reverse Transcriptase, MuLV Reverse Transcriptase Plus, Super Reverse Transcriptase MuLV, Super Reverse Transcriptase MuLV (Super RT 50 reaction kit), and RNase Inhibitor from India
Dear Mr. Khade:
In your letter dated July 31, 2020, you requested a tariff classification ruling. Additional information was provided via email on August 12, August 13, and August 24, 2020.
The five products under consideration are identified as (1) MuLV (Murine Leukemia Virus) Reverse Transcriptase, (2) MuLV Reverse Transcriptase Plus (50 Reaction kit), (3) Super Reverse Transcriptase MuLV, (4) Super Reverse Transcriptase MuLV (Super RT 50 reaction kit), and (5) RNase Inhibitor used for in-vitro scientific research purposes only, not for clinical diagnostic procedure or use. Reverse transcriptase (RT) and super reverse transcriptase are RNA-dependent DNA polymerases used to generate complementary DNA (cDNA) from an RNA template. Super reverse transcriptase is a mutated version of reverse transcriptase and has specific amino acid mutations, which increase its activity.
Product #1 (MuLV Reverse Transcriptase) and Product #3 (Super Reverse Transcriptase MuLv) both consist of two tubes packed in a plastic pouch for retail sale. One tube contains either reverse transcriptase or super reverse transcriptase mixed with a storage buffer composed of glycerol, water, NaCl, Tris HCl (CAS# 1185-53-1), EDTA (CAS# 6381-92-6), and DTT (CAS# 3483-12-3). The other tube contains a 5X reaction buffer composed of water, KCl, Tris HCl, and MgCl2.
Product #2 (MuLV Reverse Transcriptase Plus (50 Reaction kit)) and Product #4 (Super Reverse Transcriptase MuLV (Super RT 50 reaction kit)) are kits, each consisting of all components required for the synthesis of complementary DNA from RNA. Each kit consists of eight tubes packed in a retail box as a set. Tube 1 contains either reverse transcriptase or super reverse transcriptase mixed with a storage buffer. Tube 2 contains a 5X reaction buffer. Tube 3 is a mixture of water, dATP (CAS# 1927-31-7), dCTP (CAS# 102783-51-7), dGTP (CAS# 93919-41-6), and dTTP (CAS# 18423-43-3). Tube 4 is a mixture of water and an oligo (dT) primer consisting of a homogenous mixture of 12-18 nucleotide length of thymidines. Tube 5 is a mixture of water and a Random Hexamers primer, which is a mixture of oligonucleotides (dATP, dCTP, dGTP and dTTP) representing all possible sequences for a hexamer. Tube 6 is a mixture of water and DTT. Tube 7 is DEPC (CAS# 1609-47-8) treated water. Tube 8 is an RNase Inhibitor.
Product #5 (RNase Inhibitor) is a recombinant protein mixed with a storage buffer composed of glycerol, water, NaCl, Tris HCl, and EDTA, packed in a tube for retail sale. It inhibits the activity of RNases A, B and C by non-covalently binding them in 1:1 ratio and is added in the RT reaction to enhance the stability of the RNA.
The applicable classification for Products #1 and #3 listed above will be 3507.90.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "[e]nzymes; prepared enzymes not elsewhere specified or included: [o]ther." The general rate of duty will be free.
The applicable classification for Products #2 and #4 will be 3822.00.5095, HTSUS, which provides for “[d]iagnostic or laboratory reagents on a backing and prepared diagnostic or laboratory reagents, whether or not on a backing, other than those of heading 3002 or 3006; certified reference materials: [d]iagnostic or laboratory reagents on a backing, prepared diagnostic or laboratory reagents, whether or not on a backing, other than those of heading 3002 or 3006: [o]ther: [o]ther.” The general rate of duty will be free.
The applicable classification for Product #5 will be 3824.99.9297, HTSUS, which provides for “chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther.” The rate of duty will be 5 percent ad valorem.
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 (EPA). Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at (202) 554-1404, by e-mailing to [email protected], 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 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).
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 Fei Chen at [email protected]
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division