Mr. Rick Van Arnam
Barnes, Richardson & Colburn
475 Park Avenue South
New York, NY 10016

RE: The tariff classification of Lubrizol® 426E

Dear Mr. Van Arnam:

In your letter dated April 22, 2010, you requested a tariff classification ruling on behalf of Lubrizol Corporation.

The instant merchandise is described as an additive for engine oils of certain recreational vehicles and chain saws. It is a mixture of polyether, alkaryl amine, alkyl imidazoline, glycerol monoleate, hydrocarbyl amine, and a carboxylic ester. The hydrocarbyl amine is in a solvent solution that contains petroleum naphtha. You state that the MSDS for the imported product indicates that the petroleum naphtha in the imported merchandise constitutes between 1% and 4.9% of the imported product.

The applicable subheading for Lubrizol® 426E will be 3811.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: “Antiknock preparations, oxidation inhibitors, gum inhibitors, viscosity improvers, anti-corrosive preparations and other prepared additives, for mineral oils (including gasoline) or for other liquids used for the same purposes as mineral oils: Additives for lubricating oils: Containing petroleum oils or oils obtained from bituminous minerals.” The rate of duty will be 6.5 per cent 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 Paul Hodgkiss at (646) 733-3046.


Robert B. Swierupski
National Commodity Specialist Division