Ms. Dina M. Donnelly
Aceto Corporation
One Hollow Lane
Lake Success, NY 11042

RE: The tariff classification of Phenyl-2-hydroxy-4,5-dimethoxybenzoate, CAS No. 877997-98-3 from India

Dear Ms. Donnelly:

In your letter dated October 7, 2009, you requested a tariff classification ruling.

Phenyl-2-hydroxy-4,5-dimethoxybenzoate is an ester of an aromatic carboxylic acid with additional oxygen function. The product, also known as Benzoic acid, 2-hydroxy-4,5-dimethoxy-, phenyl ester, is a chemical intermediate. The chemical name indicated in your ruling request was incorrect.

The applicable subheading will be 2918.99.4300, Harmonized Tariff Schedule of the United States (HTSUS), 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: Other: Products described in additional U.S. note 3 to section VI. 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 Stephanie Joseph at (646) 733-3268.


Robert B. Swierupski
National Commodity Specialist Division