CLA-2-29:RR:NC:2:240 F80274

Mr. Vernon Kurz
BDP International Inc.
510 Walnut Street
Philadelphia, PA 19106

RE: The tariff classification of Ethyl Pyuvate (CAS # 617-35-6) and KL540 (CAS # 173903-15-6) from France

Dear Mr. Kurz:

In your letter dated November 23, 1999, on behalf of your client E.I. Dupont de Nemours, Inc., you requested a tariff classification ruling.

Ethyl Pyuvate, chemically known as 2-Oxopropanoic acid, ethyl ester, is a nonaromatic ester of a carboxylic acid. KL540, chemically known as (Chlorocarbonyl) (4-trifluoromethoxy) phenyl) carbamic acid, methyl ester, is an aromatic carboxyamide-function compound. The above chemical compounds are intermediates used in the synthesis of herbicide, insecticide and fungicide products.

The applicable subheading for Ethyl pyruvate will be 2918.30.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxylic acids with aldehyde or ketone function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Other: Other..... The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for KL540 will be 2924.29.7000, Harmonized Tariff Schedule of the United States (HTS), which provides for Carboxyamide-function compounds; amide-function compounds of carbonic acid: cyclic amides (including cyclic carbamates) and their derivatives; salts thereof: Other: Aromatic: Other: Other: Other: Products described in additional U.S. note 3 to section VI…. The rate of duty will be 9.3 percent ad valorem.

Duty on Methyl 4-trifluoromethoxyphenyl-N-(chlorocarbonyl)carbamate, CAS # 173903-15-6, entered on or before 12/31/2001, is temporarily suspended under HTS 9902.32.54.

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 212-637-7066.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division