Mr. Jonas Karlsson
Walter Kidde Portable Equipment Inc.
1016 Corporate Park Drive
Mebane, NC 27203

RE: The tariff classification of Fire Extinguisher Agents

Dear Mr. Karlsson:

In your letter dated April 12, 2013, you requested a tariff classification ruling.

In your ruling request you indicated four separate products which will be imported for use as fire extinguishing agents. They are indicated for use inside portable fire extinguishers. The products are as follows:

Part 25092 (Potassium Acetate Solution) - two 3 Liter Jugs: The product consists of a 98 percent Potassium Acetate solution (greater than 50 percent water/ 30-50 percent Potassium Acetate mixture). The product contains a coloring agent for identification purposes.

Part 23173SP AC-250 Recharge Assy - (Potassium Acetate Powder): The product consists of Potassium Acetate powder imported in bulk in 11 pound containers. It is a fire extinguishing agent used in class ABC or class BC fire extinguishers.

Part 23066 - Halotron Agent-1: The product consists of 2,2-dichloro-1,1-trifluoroethane (CAS # 306-83-2) and a proprietary gas mixture. The product is imported in reusable gas cylinders and is used to recharge fire extinguishers. Part 23702SP: The product is described as a universal ultra-alcohol resistant type of aqueous film forming foam (AR-AFFF). It consists of water, a proprietary synthetic detergent, a fluoroalkyl surfactant and a polysaccharide. It is packaged in 1 liter plastic bottles for resale. It will be sold as a fire extinguishing agent to extinguish liquid fires and to suppress the vapors that cause re-ignition (re-flash) of fires.

The applicable subheading for Part 25092 and Part 23173SP will be 2915.29.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Saturated acyclic monocarboxylic acids and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Acetic acid and its salts; acetic anhydride: Other: Other….. The rate of duty will be 2.8 percent ad valorem.

The applicable subheading for Part 23066 and Part 23702SP will be 3813.00.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Preparations and charges for fire extinguishers; charged fire extinguishing grenades: other. The rate of duty will be 3.7 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 Paul Hodgkiss at (646) 733-3046.


Thomas J. Russo
National Commodity Specialist Division