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

RE: The tariff classification of a plasticizer from Brazil

Dear Mr.Vianna de Quadros Jr.:

In your letter dated April 21, 2022, you requested a tariff classification ruling.

Innoleic™ E1 is a light-yellow liquid at ambient temperature, consisting of more than 98 percent epoxidized mono esters (CAS # 68082-35-9) with the remaining percentage of epoxidized mono- and di-glycerides and epoxidized soybean oil (CAS # 8013-07-9). The product is a mixture of various isomers of methyl esters of the various fatty acids present in the triglycerides of soybean oil, resulting from the transesterification and epoxidation reactions using soybean oil as the main raw material. The fatty acids present in the composition are mostly linoleic, oleic, palmitic, stearic, and linolenic. The transesterification reaction generates mono esters with a small proportion of mono- and di-glycerides, and some remaining unreacted soybean oil triglycerides. The epoxidation of the above mixture results in the final epoxidized mono esters and a small remaining proportion of epoxidized mono- and di-glycerides and epoxidized soybean oil. The composition of the esters may vary according to the initial composition of the soybean oil, due to original soy varieties and seasonal differences. The product is intended primarily to be used as a plasticizer for polyvinyl chloride (PVC) applications.

The applicable subheading for Innoleic™ E1 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