Mr. Christopher Colford
Mitsui & Company (USA) Inc.
200 Park Ave.
New York, NY 10166

RE: The tariff classification of Phenol, 4-((4-(4-(4-((4-(1-methylethoxy)phenyl) sulfonyl)phenoxy) butoxy)phenyl)sulfonyl)- (CAS 568572-17-8) from Japan

Dear Mr. Colford:

In your letter dated December 15, 2008, you requested a tariff classification ruling for Phenol, 4-((4-(4-(4-((4-(1-methylethoxy)phenyl) sulfonyl)phenoxy) butoxy)phenyl)sulfonyl)- which you have stated will be used as a developer for thermal paper.

In your inquiry you suggest classification in heading 2908. The compound contains aromatic organo-sulfur, alcohol, and ether, functional groups. Chapter 29, Note 3 states that “goods which could be included in two or more of the headings of this chapter are to be classified in that one of those headings that occurs last in numberical order.”

The applicable subheading will be 2930.90.2900, HTSUS, which provides for Organo-sulfur compounds: Other: Aromatic: Other: Other. The 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 World Wide Web at

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 Richard Dunkel at 646-733-3032.


Robert B. Swierupski
National Commodity Specialist Division