Mr. Alexander Boltenko
Bridge Organics/AB ChemSourcing
311 W. Washington Street
Vicksburg, Michigan 49097

RE: The tariff classification of Methyl 3,3-dimethoxypropanoate, (CAS 7424-91-1) from China

Dear Mr. Boltenko:

In your letter dated April 04, 2020, you requested a tariff classification ruling on a chemical substance called Methyl 3,3-dimethoxypropanoate (CAS # 7424-91-1) from China.

The subject chemical substance is called Methyl 3,3-dimethoxypropanoate, (CAS 7424-91-1). It consists of an organic substance containing both carboxylic acid and ether functional groups. It is also known as Propanoic acid, 3,3-dimethoxy-, methyl ester. You suggest classification for the chemical substance under Tariff subheading 2918.99.50. Based on the application of Chapter 29 Notes 1, 3 and, and Note 5 (a), we agree.

The applicable subheading for the Methyl 3,3-dimethoxypropanoate (CAS # 7424-91-1) will be 2918.99.5000, Harmonized Tariff Schedule of the United States (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.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 2918.99.5000, 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., 9903.88.16, in addition to subheading 2918.99.5000, 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.

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


Steven A. Mack
National Commodity Specialist Division