Ms. Sandi Siegel
M.E. Dey & Co., Inc.
700 W. Virginia St. Suite 300
Milwaukee, WI 53204

RE: The tariff classification of Bergalub EHO-O, CAS No. 26399-02-0, from Spain

Dear Ms. Sandi Siegel:

In your letter dated January 9, 2012, you requested a tariff classification ruling on behalf of your client Berg & Schmidt America, LLC. Your inquiry was submitted to our laboratory for analysis.

Bergalub EHO-O, CAS No. 26399-02-0, also known as 9-Octadecenoic acid ((Z)-, 2-ethylhexyl ester, is a chemical intermediate used in the production of surfactants.

The applicable subheading for the Bergalub EHO-O will be 2916.15.5100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Unsaturated acyclic monocarboxylic acids, cyclic monocarboxylic acids, their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Unsaturated acyclic monocarboxylic acids, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Oleic, linoleic or linolenic acids, their salts and esters: Other. The rate of duty will be 4.4 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.


Thomas J. Russo
National Commodity Specialist Division