Ms. Lois Mauro
P.D.M. Pharmatec Inc.
222 W. 34th Street, Suite 1505
New York, NY 10122

RE: The tariff classification of Olivetolic acid methyl ester, CAS No. 58016-28-7, and p-Mentha-2-8-dien-1-ol, CAS. No. 22771-44-4, imported in bulk form from, from India

Dear Ms. Mauro:

In your letter dated December 1, 2008 you requested a tariff classification ruling.

The chemical compound, Olivetolic acid methyl ester, also known as Benzoic acid, 2,4-dihydroxy-6-pentyl-, methyl ester, is an ester derivative of a carboxylic acid with phenol function. The chemical compound, p-Mentha-2,8-diene-1-ol, also known as 2-Cyclohexen-1-ol, 1-methyl-4-(1-methylethenyl)-, is a cycloterpenic alcohol. As stated in your letter, both products are intermediates used in the production of Dronabinol, a drug used to treat loss of appetite and severe nausea and vomiting.

The applicable subheading for p-Mentha-2,8-dien-1-ol will be 2906.19.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Cyclic alcohols and their halogenated, sulfonated, nitrated or nitrosated derivatives: Cyclanic, cyclenic or cycloterpenic: Other: Other. The rate of duty will be 5.5 percent ad valorem.

The applicable subheading for Olivetolic acid methyl ester will be 2918.29.6500, (HTSUS), which provides for Carboxylic aids with phenol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Other: Other: Products described in additional U.S. note 3 to section VI. The rate of duty will be 6.5 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 World Wide Web at

Articles classifiable under subheading 2906.19.5000, HTSUS, which are products of India may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at and search for the term “GSP”.

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 646-733-3268.


Robert B. Swierupski
National Commodity Specialist Division