CLA-2-29:OT:RR:NC:N3:140
Mr. Ryan Ervin
Genewiz Inc.
115 Corporate Blvd
South Plainfield, NJ 07080
RE: The tariff classification of Synthetic RNA from European Union, United Kingdom, or China
Dear Mr. Ervin:
In your letter dated June 02, 2021, you requested a tariff classification ruling.
You indicate that the subject merchandise consists of synthetic RNA molecules, which are nucleic acids. The artificially made RNA vary in size and usually have a molecular weight between 6 kg/mol to 1500 kg/mol or 20 nucleotides (nt) to 5,000 nt in length. You state that shipments usually consist of less than 1mg. RNA has many scientific applications, including those used for drug development and discovery or bioengineering. They can be used as a reference material for molecular assays, a probe for detecting/capturing DNA molecules, and an expression template in cellular assays. You indicate that your RNA product is strictly for non-clinical pharmaceutical or academic research purposes. Short RNAs (oligonucleotide synthesizer and long RNAs (>200nt) are usually made enzymatically by a process known as in vitro transcription. RNA can be shipped in either a liquid or a dry form. The liquid RNA is resuspended in either molecular grade deionized water or TE buffer (water + Tris-EDTA). TE buffer helps solubilize and protects the RNA from degrading. When the RNA is shipped dry, it is air dried in a vacuum. The CAS number for the RNA is 63231-63-0.
You state that the country of origin is planned to be from the European Union, United Kingdom, or China. However, you indicate that it could be any country that is legal to do business with.
The applicable subheading for the Synthetic RNA (CAS # 63231-63-0) will be 2934.99.9001, which provides for “Nucleic acids and their salts, whether or not chemically defined; other heterocyclic compounds: Other: Other: Other: Other: Other.” The general 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 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).
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division