CLA-2-39:S:N:N2:238 813906

Mr. Vernon Kurz
BDP International Inc.
1017 4th Avenue
Lester, PA 19029-1813

RE: The tariff classification of "Primellose" (Croscarmellose Sodium, CAS-9004-32-4) in powder form, from the Netherlands

Dear Mr. Kurz:

In your letter dated August 22, 1995, on behalf of your client, AVEBE America, Inc., you requested a tariff classification ruling. The submitted sample, which you refer to as "Primellose", consists of a fine, white powder composed of the sodium salt of croscarboxymethylcellulose (a cellulose ether in primary form). According to the USAN and the USP Dictionary of Drug Names, Croscarmellose Sodium ["Croscarmellose" (CAS-9000-11-7) is INN] is "Carmellose (carboxymethylcellulose) sodium that has been internally cross-linked either by control of the reaction conditions or by the use of a cross-linking reagent." You state in your letter that the subject product is used in the pharmaceutical industry as a tablet disintegrant.

The applicable subheading for the subject merchandise will be 3912.31.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for: "Cellulose and its chemical derivatives, not elsewhere specified or included, in primary forms: Cellulose ethers: Carboxymethylcellulose and its salts." Pursuant to General Note 13, HTSUSA, the rate of duty will be free. This merchandise may be subject to the regulations of the Environmental Protection Agency, Office of Pesticides and Toxic Substances. You may contact them at 402 M Street, S.W., Washington, DC 20460, telephone number (202) 554-1404) or EPA Region II at (908) 321-6669.

This ruling is being issued under the provisions of Section 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 C. Reilly at (212) 466-5770.


Roger J. Silvestri
National Commodity
Specialist Division