Mr. Maurice J. Deslauriers
Norman G. Jensen, Inc.
199 East Orvis Street, Suite #2
Massena, NY 13662

RE: The tariff classification of MetaAid citric acid aqueous solutions from Canada

Dear Mr. Deslauriers:

In your letter dated January 25, 2011, you requested a tariff classification ruling on behalf of your client Metafix Inc.

MetaAid CA04, MetaAid CA06, MetaAid CA20, and MetaAid CA50 are formulated citric acid aqueous solutions utilized in the neutralization of waste printing inks. Each formulated MetaAid citric acid aqueous solution has a specified amount of citric acid, as noted in the product suffix indicator.

You inquiry pertains to the classification of citric acid aqueous solutions and whether they are considered blends or mixtures for tariff purposes. MetaAid citric acid aqueous solutions are composed of a separate chemically defined compound and water.

Legal Note 1 to Chapter 29, HTSUS, reads, in pertinent part: Except where the context otherwise requires, the headings of this chapter apply only to: (a) Separate chemically defined organic compounds, whether or not containing impurities and (d) Products mentioned in (a), (b) or (c) above dissolved in water. Aqueous solutions of the separate organic chemical compounds of Chapter 29 remain classified within that Chapter. MetaAid CA04, MetaAid CA06, MetaAid CA20, and MetaAid CA50 are separate chemically defined compounds dissolved in water. The products are not considered blends or mixtures for tariff purposes; therefore, they are classified as separately chemical defined compounds of Chapter 29.

The applicable subheading for MetaAid CA04, MetaAid CA06, MetaAid CA20, and MetaAid CA50 will be 2918.14.0000, 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: Carboxylic acids with alcohol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Citric acid. The rate of duty will be 6 percent ad valorem.

Citric acid of Canadian origin may be subject to antidumping duties or countervailing duties. Written decisions regarding the scope of AD/CVD orders are issued by the Import Administration in the Department of Commerce and are separate from tariff classification and origin rulings issued by Customs and Border Protection. You can contact them at (click on "Contact Us"). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at (click on "Antidumping and countervailing duty investigations"), and you can search AD/CVD deposit and liquidation messages using the AD/CVD Search tool at (click on "Import" and "AD/CVD").

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