Mr. Noah Sondov-Gold
Gold Biotechnology, Inc.
1328 Ashby Road
St. Louis, MO 63132

RE: The tariff classification of various chemical compounds in bulk form, from China

Dear Mr. Sondov-Gold:

In your letter dated June 15, 2018, you requested a tariff classification ruling on five chemical compounds that will be used for scientific research. Below are the descriptions you provided on the following chemicals:

Item 1 Cefsulodin (SCE-129, CAS No. 52152-93-9) is a third generation cephalosporin antibiotic used as a selective agent in isolation media such as Yersinia Selective Agar, Columbia Blood Agar, Salmonella Chromogenic Agar, and CIN Agar. It is mildly effective against gram-positive and gram-negative bacteria, but exhibits greater efficacy against Pseudomonas aeruginosa. In addition to its antimicrobial properties, cefsulodin is a substrate for the rat Oatp1a4 transporter. The product is imported as an off-white to slightly yellow crystalline powder.

Item 2 NAD (ß-Nicotinamide Adenine Dinucleotide, CAS No. 53-84-9) is a required oxidizing cosubstrate for many enzymes. NAD+ is capable of donating ADP-ribose moieties to a protein, producing nicotinamide in the process. Sirtuin enzymes use NAD+ as a substrate to deacetylate proteins and direct activity between the nucleus and mitochondria. NAD+ is regenerated by fermentation and by oxidative phosphorylation. The product is imported as a white to yellowish powder.

Item 3 Cantharidin (CAS No. 56-25-7) is a natural toxin inhibitor of protein phosphatases 1 and 2A. Cantharidin also stimulates cell cycle progression and induces premature mitosis. The product is imported as a white to off-white crystalline powder.

Item 4 D-Biotin (also known as vitamin H or coenzyme R, CAS No. 58-85-5) is a water-soluble member of the B vitamins (B7). During fatty acid synthesis and gluconeogenesis, biotin acts as a flexible prosthetic group by allowing it to reach different enzymatic active sites. Biotin can be used in cell culture media for its involvement in a number of cellular processes including gluconeogenesis, synthesis of fatty acids, and amino acids isoleucine and valine. The product is imported as a white or off-white powder. According to our research, D-biotin is the naturally occurring, biologically active form of the B vitamin biotin.

Item 5 Bestatin (CAS No. 58970-76-6) is a reversible protease inhibitor. Bestatin is an aminopeptidase inhibitor and inhibits tumor cell proliferation. The product is imported as a white to off-white crystalline powder. According to our research, Bestatin is also known as Ubenimex (INN), which is derived from Streptomyces olivoreticuli and has the ability to kill or inhibit the growth of microorganisms and neoplasms.

The applicable subheading for Cefsulodin will be 2941.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Antibiotics: Other: Other: Aromatic or modified aromatic.” The rate of duty will be free.

The applicable subheading for NAD (ß-Nicotinamide Adenine Dinucleotide) will be 2934.99.4400, HTSUS, which provides for “Nucleic acids and their salts; whether or not chemically defined; other heterocyclic compounds: Other: Other: Aromatic or modified aromatic: Other: Other: Other.” Pursuant to GN 13, HTSUS, the rate of duty will be free. NAD is also known as Nadide, which is listed in Table 1 of the Pharmaceutical Appendix to the Tariff Schedule.

The applicable subheading for Cantharidin will be 2918.99.5000, HTSUS, which provides for “Carboxylic acids with additional oxygen function and their anhydrides, halides, peroxides and peroxyacids; their halogenated, sulfonated, nitrated or nitrosated derivatives: Other: Other: Other.” The rate of duty will be 4 percent ad valorem.

The applicable subheading for D-Biotin will be 2936.29.5030, HTSUS, which provides for “Provitamins and vitamins, natural or reproduced by synthesis (including natural concentrates), derivatives thereof used primarily as vitamins, and intermixtures of the foregoing, whether or not in any solvent: Vitamins and their derivatives, unmixed: Other vitamins and their derivatives: Other: Other: Biotin.” The rate of duty will be free.

The applicable subheading for Bestatin will be 2941.90.1050, HTSUS, which provides for "Antibiotics: Other: Natural: Other." The rate of duty will be free.

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 merchandise may be subject to the Federal Food, Drug, and Cosmetic Act and/or The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (The Bioterrorism Act), which are administered by the U.S. Food and Drug Administration (FDA). Information on the Federal Food, Drug, and Cosmetic Act, as well as The Bioterrorism Act, can be obtained by calling the FDA at 1-888-463-6332, or by visiting their website at

This merchandise may also be subject to the requirements of the Toxic Substances Control Act (TSCA), which are administered by the U.S. Environmental Protection Agency. Information on the TSCA can be obtained by contacting the EPA at 1200 Pennsylvania Avenue, N.W., Mail Code 70480, Washington, D.C., by telephone at (202) 554-1404, or by visiting their website 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 Judy Lee at


Steven A. Mack
National Commodity Specialist Division