CLA-2-29:S:N:N1-F:238 868436

Ms. Gayle A. Agnello
Vinchem Inc.
354 Main Street
P.O. Box 639
Chatham, NJ 07928

RE: The tariff classification of Naproxen, Naproxen Sodium, and Tolnaftate, in bulk form, from Italy.

Dear Ms. Agnello:

In your letter dated October 25, 1991, you requested a tariff classification ruling.

Naproxen (CAS-22204-53-1) and Naproxen Sodium (CAS-26159-34- 2) are drugs, each of which functions as an anti-inflammatory, analgesic, and anti-pyretic agent. Tolnaftate (CAS-2398-96-1) is an antifungal drug.

The applicable subheading for Naproxen and Naproxen Sodium will be 2918.90.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for carboxylic acids with additional oxygen function and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: other: aromatic: other: drugs. The rate of duty, if entered on or before December 31, 1992, will be free. The applicable subheading for Tolnaftate will be 2930.20.2050, HTS, which provides for organo-sulfur compounds: thiocarbamates and dithiocarbamates: aromatic: other, other. The rate of duty will be 3.7 percent ad valorem. Your inquiry does not provide enough information for us to give a classification ruling on Ipratropium Bromide. Your request for a classification ruling should include the manufacturing process flow chart and the source from which this product was produced. This merchandise may be subject to the regulations of the Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number (202) 443-3380. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director
New York Seaport