Mr. Andrew B. Rogers
3V Sigma USA Inc.
888 Woodstock Street
Georgetown, SC 29440

RE: The tariff classification of 1,1,3,3-tetramethylbutylamine from China

Dear Mr. Rogers:

In your letter dated September 20, 2019, you requested a tariff classification ruling.

The subject product is called 1,1,3,3-tetramethylbutylamine (CAS # 107-45-9). It is also known as 2-Pentanamine, 2,4,4-trimethyl and tert-Octylamine. The chemical structure contains a single amine group with a five length carbon as its longest chain (pentanamine).

The applicable subheading for the 1,1,3,3-tetramethylbutylamine (CAS # 107-45-9) will be 2921.19.6190, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Amine-function compounds: Acyclic monoamines and their derivatives; salts thereof: Other: Other: Other: Other." The rate of duty will be 6.5 percent ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 2921.19.6190 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 subheading 2921.19.6190, 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 and respectively.

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 ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

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

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 [email protected].


Steven A. Mack
National Commodity Specialist Division