Mr. Jacyr Vianna de Quadros Jr.
Innoleics USA Corp.
806 Verona Street, Suite 1
Kissimmee, FL 34741

RE: The tariff classification of PVC plasticizers from Brazil

Dear Mr. Vianna de Quadros Jr.:

In your letter dated February 1, 2022, you requested a tariff classification ruling. Additional information was received by email on February 8, 2022.

Innoleic™ MB 25 and Innoleic™ MB 50 are a light-yellow liquid at ambient temperature, consisting of approximately 15 - 40 percent of epoxidized methyl soyate (CAS# 68082-35-9), 10 - 50 percent epoxidized soybean oil (CAS# 8013-07-9), and 10 - 50 percent acetylated mono- and di-glycerides of epoxidized soybean oil (CAS# 2097734-14-8). The products are reaction mixtures, which are a result of a sequence of three reactions with soybean oil as the raw material: (1) partial transesterification, generating mono-esters, mono- and di-glycerides, with some remaining unreacted soybean oil (triglycerides); (2) acylation, where hydroxyl groups of mono- and di-glycerides are acylated (or acetylated); and (3) epoxidation of the mixture, resulting in the final epoxidized mono esters, epoxidized acylated mono- and di-glycerides, and epoxidized soybean oil. They are intended primarily to be used as plasticizers for polyvinyl chloride (PVC) applications.

The applicable subheading for Innoleic™ MB 25 and Innoleic™ MB 50 will be 3812.20.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides, in pertinent part, for “compound plasticizers for rubber or plastics, not elsewhere specified or included ... [c]ompound plasticizers for rubber or plastics: ... [o]ther.” The general rate of duty will be 5 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 World Wide Web at

This merchandise may 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 800-471-7127, by e-mailing to [email protected], 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 Fei Chen at [email protected].

Steven A. Mack Director National Commodity Specialist Division