Mr. John M. Gurley
1050 Connecticut Ave. NW
Washington, DC 20036-5339
RE: The tariff classification of Tocopherol compositions of T130 and T155.
Dear Mr. Gurley:
In your letter dated October 12, 1998, on behalf of your client Henkel
Corporation, you requested a tariff classification ruling for Tocopherol
compositions of T130 and T155.
You state in your inquiry that imported vegetable oil distillate will be
entered into a Foreign Trade Zone (FTZ) and processed into finished
Tocopherols (T130 and T155) which are composed of tocopherol, sterols and
unsaponifiables. Despite the further processing, T130 and T155 still do not
meet the requirements for classification as a vitamin E concentrate under HTS
subheading 2936.28.0000. The products do not contain the required percentage
of d-alpha tocopherols, nor are the final products (Covoix and Covitol) used
for their vitamin activity.
The applicable subheading for T130 and T155 will be 3824.90.2800,
Harmonized Tariff Schedule of the United States (HTS), which provides for
prepared binders for foundry molds or cores; chemical products and
preparations of the chemical or allied industries (including those consisting
of mixtures of natural products), not elsewhere specified or included;
residual products of the chemical or allied industries, not elsewhere
specified or included: other. The rate of duty will be 2.2 cents per
kilogram plus 10.8 percent ad valorem.
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 Thomas Brady at (212)466-5747.
Robert B. Swierupski