Patricia Choo
ITOCHU International, Inc.
335 Madison Avenue
New York, NY 10017

RE: The tariff classification of four grades of Duranate from Japan

Dear Ms. Choo:

In your letter dated February 23, 2016, you requested a tariff classification ruling.

The merchandise at issue consists of four grades of Duranate, identified as TKA-100, TLA-100, 24A-100, and TKA-90SB. Per your submission the four grades consist of hexamethylene diisocyanate (HDI) based polyisocyanates for polymerization and cross-linking of high-weatherability polyurethanes. You indicate that the products are used in the manufacture of weather-resistant paints and coatings for the automotive industry.

While the products are referred to as polyurethanes, HDI does not meet the definition of a polyurethane produced by the reaction of polyfunctional isocyanates with polyhydroxy compounds, as described by Harmonized System Explanatory Note 3 to heading 3909. Consequently, the products would be classified in heading 3911.

The applicable subheading for the Duranate grades TKA-100, TLA-100, 24A-100, and TKA-90SB will be 3911.90.2500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other products specified in note 3 to this chapter, not elsewhere specified or included, in primary forms: Other: Other: Containing monomer units which are aromatic or modified aromatic, or which are obtained, derived or manufactured in whole or in part therefrom: Thermoplastic: Other. The rate of duty will be 6.1% 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 Evan Conceicao at [email protected]


Deborah C. Marinucci
Acting Director
National Commodity Specialist Division