Mr. Noah Sondov-Gold
Gold Biotechnology, Inc.
1328 Ashby Road
St. Louis, MO 63132
RE: The tariff classification of various chemical compounds from China
Dear Mr. Sondov-Gold:
In your letter dated July 3, 2019, you requested a tariff classification ruling. We apologize for the delay as the information was sent to our laboratory for analysis.
You indicated all of the following items are used for research at laboratories and universities. Below are the descriptions you provided on the following chemicals:
n-Dodecyl-B-D-maltoside (DDM) (CAS No. 69227-93-6) is a maltoside based non-ionic detergent with a hydrophilic maltose head and a hydrophobic long chain alkyl tail. The primary attribute of DDM is its capability to extract hydrophobic proteins while maintaining the solution-phase protein conformation. The product is imported as a white to slightly off-white powder. The product's country of origin is China.
G-418 sulfate (CAS No. 108321-42-2) is an aminoglycoside antibiotic similar in structure to gentamicin B1. It is commonly used in plant and mammalian cell culture as a selectable marker. It can be used to select for cells transformed with an iNOS promoter construct or neomycin resistance gene. G-418 functions by causing a chain of nonsense mutations during translation, ultimately resulting in inhibition of polypeptide synthesis and protein elongation. The product is imported as a white powder. The product's country of origin is China.
Proteinase K (CAS No. 39450-01-6) is a highly reactive nonspecific serine protease that belongs to the subtilisin family of proteins. It cleaves at the carboxylic acid side of aliphatic, aromatic, or hydrophobic amino acids. Proteinase K is capable of inactivating RNases and DNases and is used in the isolation or preparation of high molecular weight nucleic acids. This enzyme was designated proteinase K because of its ability to hydrolyze keratin. Proteinase K is stable in a wide variety of detergents and buffer salts and at various temperatures and pH. The product is imported as a white lyophilized powder. The product's country of origin is China.
Pepstatin A (CAS No. 26305-03-3) is a competitive, reversible aspartic protease inhibitor and inhibits proteases such as pepsin, chymosin, renin, HIV proteases, and cathepsins D and E. Peptstatin A is highly selective and is often used in a mixture with other enzyme inhibitors. Pepstatin A is effective at inhibiting most affected proteases at a concentration of 1M, but can inhibit pepsin at the picomolar range of concentrations. The product is imported as a white to off-white powder. The product's country of origin is China.
Diethylpyrocarbonate (DEPC) (CAS No. 1609-47-8) is a moisture sensitive product that will readily decompose to ethanol and carbon dioxide in aqueous solution. DEPC can inhibit ryanodine binding to the ryanodine/Ca2 + receptor channel in a dose-and time-dependent manner, or work as a nuclease inhibitor. DEPC is often used to treat water used in the handling of RNA to remove RNases and reduce the risk of the RNA being degraded. The product is imported as a clear, colorless liquid. The product's country of origin is China.
The applicable subheading for item 1, n-Dodecyl-?-D-maltoside (CAS No. 69227-93-6), will be 3402.13.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Organic surface-active agents, whether or not put up for retail sale: Nonionic: Other: Other." The general rate of duty will be 3.7 percent ad valorem.
The applicable subheading for item 2, G-418 sulfate (CAS No. 108321-42-2) will be 2941.90.1050, HTSUS, which provides for "Antibiotics: Other: Natural: Other." The general rate of duty will be free.
The applicable subheading for item 3, Proteinase K (CAS No. 39450-01-6) will be 3507.90.7000, HTSUS, which provides for: "Enzymes; prepared enzymes not elsewhere specified or included: Other: Other." The general rate of duty will be free.
The applicable subheading for item 4, Pepstatin A (CAS No. 26305-03-3) will be will be 2924.19.8000, HTSUS, which provides for "Acyclic amides (including acyclic carbamates) and their derivatives; salts thereof: Other: Other." Pursuant to General Note 13, HTS, the rate of duty will be free.
The applicable subheading for item 5, Diethylpyrocarbonate (CAS No. 1609-47-8) will be 2920.90.5100, HTSUS, which provides for "Esters of other inorganic acids of nonmetals (excluding esters of hydrogen halides) and their salts; their halogenated, sulfonated, nitrated or nitrosated derivatives: Other: Other." The general 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 the World Wide Web at https://hts.usitc.gov/current.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 2924.19.8000; 3402.13.5000; 3507.90.7000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheadings 2924.19.8000; 3402.13.5000; 3507.90.7000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 2920.90.5100, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 2920.90.5100, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.
The G-418 sulfate (CAS No. 108321-42-2) 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 www.fda.gov.
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 (EPA). Information on the TSCA can be obtained by contacting the EPA at Document Control Office (7407M), Office of Pollution Prevention and Toxics (OPPT), Environmental Protection Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C., 20460, by calling the Toxic Substances Control Act Hotline at (202) 554-1404, by e-mailing to firstname.lastname@example.org, or by visiting their website at www.epa.gov.
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 Judy.email@example.com.
Steven A. Mack
National Commodity Specialist Division